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  • By looking beyond traditional definitions of rent, Claire Jones finds out that it is more than just property companies that can profit from the UK's Reit regime
  • Sean Foley The US Treasury Department and the IRS have released final regulations (T.D. 9315) concerning dual consolidated losses (DCLs) under section 1503(d) of the Internal Revenue Code. The final regulations address various DCL issues, including exceptions to the general prohibition against using a DCL to reduce the taxable income of any other member of the affiliated group. The regulations are intended to prohibit a US corporation from taking a deduction for U.S. tax purposes if that same deduction could be used to offset income in a foreign country. The regulations were issued to update the prior regulations to reflect changes in US and foreign law. The regulations:
  • Kevin Rowe Edward Tanenbaum Treasury and IRS have finalised regulations under section 871(h) that apply an aggregate concept to determine whether US source interest received by a partnership is "portfolio interest" exempt from withholding tax. The final regulations adopt the aggregate approach and may apply retroactively to interest paid in prior years.
  • Castor Garate Biscay enjoys a considerable degree of autonomy in tax matters, including tax legislation. This power was recently confirmed by the reasoning of the European Court of Justice (ECJ). Biscay is an infra-state body which has, from a constitutional point of view, a political and financial status separate from the central government within the meaning of the ECJ's judgement of September 6 2006, Portuguese Republic vs. Commission of the European Communities (case C-88/03).
  • Roberto del Toro Adriana Rodriguez On May 8 2007 a decree announcing the new tax treaty between Mexico and New Zealand was published in the Official Gazette, it was approved on April 11 2007 and signed on November 16 2006. This treaty will become effective 30 days after each country has notified the other of the completion of its ratification. In Mexico, its provisions regarding income subject to withholding tax will apply beginning on the first day of the second month following its entry in force; its other provisions will apply beginning January 1 of the next year.
  • Hans Olav Hemnes The current tax treaty Norway has with the US is from 1971, last updated in 1980, which means that it is fairly old fashioned.
  • By Catherine Snowdon
  • Roland Brandsma and Suzanne Boers of PricewaterhouseCoopers praise the virtues of the new Dutch participation exemption
  • Singapore, Asia's biggest oil trading centre, has announced tax breaks on income from liquefied natural gas (LNG) and carbon emission transactions to encourage overseas companies to invest in the city-state.