Search results for

Neil Wilson The US Financial Accounting Standards Board (FASB) interpretation no. 48, Accounting for Uncertainty in Income Taxes, and Interpretation of FASB Statement No. 109 (FIN 48) has been a hot topic of discussion lately. In essence, FIN 48 directs US reporting companies as to how under the Generally Accepted Accounting Principles (GAAP) they should account for uncertain tax positions in their corporate financial accounts.

Rajendra Nayak Ganesh Pai The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of Western Union Financial Services Inc. vs. ADIT [2007] 291 ITR (AT) 176 examined the taxability of a foreign company carrying out money transmission services. The taxpayer, a tax resident of US, was a company incorporated in the US and was engaged in the business of rendering money transfer services across international borders. For its activities in India, the taxpayer appointed agents in India who were compensated by way of commission.

Paul Stepak When a Canadian subsidiary of a multinational business borrows money from third parties, the borrowing is often guaranteed by a foreign parent (or another affiliate). Certainly there are good commercial reasons why such guarantees are provided, namely to improve the credit quality of the indebtedness thereby reducing the third-party financing costs for the Canadian subsidiary. It seems reasonable to expect that the parent might charge a guarantee fee in such circumstances and that under the domestic transfer pricing rules in the parent's jurisdiction such a fee (set at arm's length terms) might be required (or deemed to be paid).

Andrés Edelstein Ignacio Rodríguez After Congress approval, on August 10 2007 the Argentine Executive Branch has enacted an amendment protocol signed six years ago between Argentina and France to their 1979 double tax treaty (Law 26,276).

Jaroslaw Antosik, of Accreo Taxand in Poland, argues that the Polish taxpayer's right to be properly informed is a continuing process

Dublin financial centre: OECD target Ireland's low corporate tax rates are expected to come under attack from the tax intermediaries group of the Organisation for Economic Cooperation and Development (OECD). The group, which is expected to report in December, is believed to be critical of Ireland's tax policy which is central to its inward investment regime.

The United States government has said it will go to court to challenge European plans to impose a carbon tax on airlines.

The Revenue & Customs has targeted private banks as part of its initiative to limit tax evasion through offshore accounts.

Lazslo Kovacs A majority of pan-European businesses support the common consolidated corporate tax base, says a major new survey from KPMG.

Mexico city On September 17 2007, the Mexican Congress approved a tax bill for 2008 which will, among other significant developments, introduce a flat business tax rate.