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Sean Foley Landon McGrew The US Tax Court recently issued an opinion, in Highwood Partners v CIR, 133 TC No 1 (2009), holding that an extended six-year statute of limitations period applied to a taxpayer's tax return because the taxpayer failed to separately compute and report its foreign currency gain and loss under section 988 and none of the relevant returns adequately disclosed the nature or amount of the omitted income.

Ramakrishna Sithanen, the vice prime minister, minister of finance and economic empowerment, presented his fifth and last budget speech under the mandate of the present government.

Alke Fiebig Recent events have cast new light on the well-known debate within tax authority circles on the privileges for private equity funds. In the past, there was little reason for foreign funds to fear a German tax authority assumption of residency, as long as they confined their local activities to collecting deposits from German investors. The cash was then transferred abroad and invested under the control of foreign managers. Effectively, the German affiliate merely acted as coordinator, or liaison agent, for local depositors and as an adviser to the foreign fund management on German investment and market conditions. It did not generate business income attributable to the fund as such.

Ingrid Anne Kinden In accordance with the Norwegian Tax Act, dividends distributed by a Norwegian corporation to an entity located in another EEA country are 100% exempt from withholding tax if the recipient "corresponds to" a Norwegian entity that qualifies for an exemption on dividends received from a Norwegian corporation. However, the recipient must meet a substance test by having an "actual establishment" and performing "real economic activities" in its home country.

Tax professionals in the UK are split about what's likely to be in next week's pre-budget report

Vicente Bootello José Ignacio Ripoll In the second half of this year, the Spanish government has been carrying out an important reform of several aspects of the Spanish tax system. This governmental reform is expected to affect, among other taxes, corporate tax, for which the most noteworthy change is the possibility of reducing the shareholding stake required to form a consolidated tax group.

Henry An David Jin-Young Lee In October 2009, the National Tax Service (NTS) announced the introduction of the horizontal tax compliance program. The program is intended to reduce uncertainties in the interpretation of tax rules, decrease the costs of tax compliance, and enhance transparency and trust. It will also enhance the ability of the tax authorities to promptly respond to taxpayer requests and achieve a high level of tax compliance.

Janne Juusela On November 6 2009 the Finnish government issued a bill proposing amendments to the Finnish tonnage tax regime. The proposed amendments aim to promote the international competitiveness of the Finnish shipping industry and the employment of the branch in question. The new tonnage tax regime offers tax incentives to Finnish shipowners and encourages shipowners to new investments and to bring ships under the Finnish flag.

Luis Avello Before January 9 2007, the withholding tax rate applied to services, distinguished between technical assistance and engineering services; and non technical services to determine the tax rate applied. At the time, technical assistance services and engineering services benefited from a lowered withholding tax rate of 20% in comparison with non technical services or non engineering services, which were subject to the general 35% rate. In this sense, the historical interpretation held by the Chilean Internal Revenue Service (SII) regarding technical assistance services was that technical assistance services were technical or professional services that a person with specific knowledge of a science or technique renders throughout a recommendation, report or blueprint (private ruling number 4.587 of 2000).

Italy's withholding tax rules on dividends distributed to overseas recipients breach provisions of the European Treaty. Philippe Freund of Dorsey & Whitney explains why