Search results for

Sean Foley Recently, the IRS Large and Midsize Business Division (LMSB) issued a new industry directive (LMSB-04-0407-035) focusing increased audit efforts on certain international hybrid instrument transactions. International hybrid instrument transactions are cross-border financing arrangements in which the taxpayer takes different positions in its treatment of the transaction as debt or equity for US and foreign tax purposes.

Manuel Bouzas Transfer pricing is an issue of growing importance in the international arena, owing to the globalisation of the economy and the absence of fiscal harmonisation. The OECD is well aware of this and has concentrated much effort on establishing a series of criteria which will enable states to approach the problem in a manner which is as uniform as possible, fostering cooperation between the tax authorities of the different states in areas such as information exchange and joint inspection procedures.

Suzanne Boers When employees are temporarily hired out to work cross border at a foreign affiliated company of their own employer, the question can be raised as to which of the two states involved may levy tax on the wages. Double tax conventions contain several criteria and conditions in order to divide the taxing powers on income elements such as wages between the contracting states.

Roberto del Toro Salvador Esquivel The tax treaty between Mexico and the Slovak Republic was signed on May 13 2006 and approved on July 13 2007. The treaty will enter into force 60 days after each country has notified the other of the completion of its ratification. All treaty provisions will apply as from January 1 of the calendar year following its entry in force.

Akio Takisaki The rules limiting the tax deductibility of director's compensation payments, which were substantially revised in the 2006 tax reform, have been further amended in the 2007 tax reform. The new provisions are applied in the taxable year starting on or after April 1 2007.

Kleinbard US Congress has chosen a corporate tax lawyer from Wall Street as the next chief of staff of the US Joint Committee on Taxation. Edward Kleinbard moves from a 30-year career advising institutional investors on M&A and financial products at Cleary Gottlieb Steen & Hamilton in New York to his new role in Washington on September 17.

Grant Thornton in America has appointed a new head of transfer pricing. David Bowen has joined from the Internal Revenue Service where he worked in the associate chief counsel's office.

Moisés Curiel, Carlos Linares and Eduardo Méndez discuss how transfer pricing have changed since their introduction

Henry An The National Tax Service (NTS) announced its tax audit directive for 2007 in July. The NTS indicated that the percentage of corporate taxpayers selected for tax audit would again be reduced, but that those selected for tax audit would be subject to more intense scrutiny. Specifically, the percentage of corporate taxpayers selected for tax audit would decrease from 0.9% in 2006 to 0.8% in 2007, which represents approximately 2,800 companies.

America's 12th largest accountant Moss Adams has recruited Michael Ferguson as a partner in its international services group. He was formerly international tax services leader for Ernst & Young in Seattle and Portland.