ITR Search | International Tax Review

Bird & Bird gains a partner

Patrick Sinewe, who specialises in restructuring and group tax law as well as on M&A, leveraged buy-out and private equity related tax issues has become a partner of Bird & Bird in Frankfurt.

April 30 2009

Tax deduction for final losses in subsidiaries within the EEA

Rikard Ström Weronica Sjöberg On March 11 2009, the supreme administrative court issued judgments in 10 cases regarding the Swedish group contribution system, which is the Swedish method of group relief, and its compatibility with the EC treaty with respect to losses in group entities within the EEA.

April 30 2009

IRS clarifies term under the US-Belgium treaty

Sean Foley The IRS rece-ntly posted interim guidance on its website clarifying the meaning of the term commen-cement date for purposes of the mandatory arbitration process in mutual agreement procedure (MAP) cases under the US-Belgium income tax treaty. The interim guidance was generally welcomed by taxpayers because, pending publication of more formal procedures, the interim guidance could prevent unnecessary delays in resolving MAP cases under consideration by the US and Belgium competent authorities.

April 30 2009

Steinberg heads back to private practice

Lewis Steinberg has left UBS to join Linklaters as co-head of the US practice and head of US tax.

April 30 2009

Revolutionary VAT changes for taxation of services from 2010

After years of negotiation, the European Council has finally reached a political agreement on the changes proposed in the VAT package. The aim of this VAT package is to minimise the administrative burden for companies engaged in cross border trade, to ensure that VAT on services accrues to the country where consumption occurs and to prevent distortions of competition between member states operating different VAT rates.

April 30 2009

Exemption for select credit guarantee institutions announced

Stephen Nelson Aiming to support small and medium-sized enterprises to survive the global financial crisis, the Ministry of Industry and Information Technology and the State Administration of Taxation jointly issued the notice on business tax exemption for small and medium-sized enterprise credit guarantee institutions (Gong Xin Bu Lian Qi Ye [2009] number 114) on March 31 2009.

April 30 2009

DLA expands tax practice

US law firm DLA Piper has expanded its international tax practice with the appointment of three transfer pricing specialists: two principal economists and one of counsel. Clarke Norton has 17 years transfer pricing experience and was formerly chief economist of the Inland Revenue Service's Advance Pricing Agreement Program.

April 30 2009

Temporary regulations close repatriation loophole

Edward Tanenbaum The Internal Revenue Service (IRS) issued temporary regulations on the application of section 367 of the Internal Revenue code in cross-border stock transfers governed by code section 304. The temporary regulations are intended to stop a transaction used by some taxpayers to repatriate cash to the US tax-free.

April 30 2009

Skadden gains two partners

Sean Shimamoto Sean Shimamoto and Steven Matays have become partners of Skadden, Arps, Slate, Meagher & Flom's tax practice. Shimamoto, in the firm's Washington DC, office, represents major corporations and private equity funds on US federal income tax matters, including M&A, debt and equity offerings and joint ventures. His practice also covers tax matters in the energy sector. He also advises clients on tax matters in the energy sector, particularly involving renewable energy projects.

April 30 2009

First UK verdict focuses on appropriate outcome

Mark Atkinson and Richard Coombes of Deloitte in London believe that the decision in the first UK transfer pricing case in more than 20 years shows that taxpayers need a good reason to base a transaction in a low-tax jurisidiction

April 30 2009

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