ITR Search | International Tax Review

Decision on exchange difference causes uncertainty

Rolf Wüthrich of VISCHER explains the latest Swiss federal Supreme Court decision on the treatment of exchange differences resulting from the year end conversion of financial statements kept in non-Swiss functional currency into Swiss francs

March 31 2010

Different policy upsets information exchange

Marcel Widrig of PricewaterhouseCoopers explains how Switzerland has amended its practice on exchange of information since 2009 and what impact this has had on the international agreements it has signed up to

March 31 2010

Editorial

Switzerland moves ahead with reform

March 31 2010

Switzerland: Holding companies get legislative boost

The new VAT regime and other developments in its tax law make Switzerland even more attractive as location for holding companies and international group companies with financing activities there, believe Markus Prinzen, Mathias Bopp, Marcel Angehrn and Timo Haack of PricewaterhouseCoopers

March 31 2010

Earn-out complicates SuccessFactor deal

Erin Kelechava reports on the tax issues surrounding rewards for the executives of an Australian business software company acquired by a US rival

March 31 2010

How transfer pricing methods have developed for asset management

Dieter Wirth and Mohamed Serokh of PricewaterhouseCoopers in Switzerland look at how multinationals such as banks and insurance groups operating in Zurich have been treated during tax audits focusing on the different transfer pricing methods

March 31 2010

UK: Doubts continue to undermine transactions

The possibilities for using the tax assets of a UK acquisition are dogged by uncertainties this year, not least the possible reform of controlled foreign company rules, point-out Mike Lane and Stephen Edge of Slaughter and May

March 31 2010

Alvarez & Marsal Taxand hires employment specialist

Colin Keane Colin Keane has joined Alvarez & Marsal Taxand as a senior director in its London office. He was formerly employment solutions director for PricewaterhouseCoopers in the London and, before this, head of operational and employment tax at Barclays, the bank. He will advise Alvarez & Marsal Taxand's clients on a wide range of employment tax issues.

March 31 2010

Temporary regulations address avoidance of section 304

Edward Tanenbaum Tola Ozim The IRS has issued temporary regulations amending temporary Treasury regulations Section 1.304-4T regarding the use of controlled corporations to avoid the application of Code section 304. The prior and current temporary regulations aim to make it more difficult to avoid section 304 dividend treatment in transactions to which the section applies.

March 31 2010

FTI Consulting hires former Treasury adviser

Chris Wales, a former adviser on taxation to the chancellor of the exchequer in the UK, has joined FTI Consulting, a global business advisory firm, as a senior managing director in its economic consulting practice in London. He will help to develop the firm's combined economic and public policy division which advises multinational corporations and governments. He will also work closely with FTI's litigation division, principally on tax-related issues.

March 31 2010

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