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.

The three Benelux states – the Netherlands, Belgium and Luxembourg – are passionate believers in using the tax system to facilitate direct investment. They use every opportunity to refine and develop the regime to create greater economic growth.

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.

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.

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

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.

Peter Dutton A draft tax bill, published by Peter Dutton, the minister for revenue, on August 16, aims to change the rules in Australia on thin capitalisation, company tax losses, capital gains tax for statutory licences, property trusts and stapled securities.

Andrés Edelstein Ignacio Rodríguez The national tax court (Tribunal Fiscal de la Nación or TFN), which is not strictly speaking a court but an administrative tribunal specialised in the resolution of tax and customs matters, has recently issued an opinion challenging the deductibility of interest stemming from loans granted to an Argentine holding company to buyout an Argentine operating company. The acquisition was followed by a tax-free reorganisation (upstream merger) between the two Argentine entities.

Sempra Metals won a landmark victory in the UK House of Lords in July. Clive Greenwood, joint head of partnerships and LLPs at Lewis Silkin in London, explains how a revenue interpretation was contrary to European law

Vodafone and the UK tax authorities will return to the Special Commissioners for another hearing in a dispute over the country's controlled foreign companies (CFC) legislation and a Luxembourg subsidiary of the mobile communications company.