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  • Sean Foley The IRS has released Rev. Proc. 2007-23, which provides rules allowing taxpayers to change to or continue to use the Net Consideration Method with respect to a qualified patent cross licensing arrangement (QPCLA). In summary, the IRS has agreed that cross license payments for patents can be netted against each other for withholding tax and certain other tax purposes.
  • By Reece Jenkins, Ernst & Young
  • By Tobias Lintvelt, Kazuhiro Mukaida and Rhett Shaver, Ernst & Young, Japan
  • A layer of the tax system exists out there that tax directors cannot ignore. Regional taxes are not common to every country, but where they do appear executives can either be lucky or unlucky. They could have a pain-free ride tor they could get so bogged down in complexity that pulling teeth without anaesthesia might seem like an easier choice.
  • Frank Schmidt A small business purchased a generic internet domain name, based on the name of a river, from the previous registrant, an internet service company.
  • Kumar Girish from BSR & Co and Caren Shein from KPMG look at India's dividend distribution and the IRC
  • Taxpayers should generally find it easier to manage their affairs in France following the new Finance Act and changes to last year's version, believe Ambroise Bricet, Marie-Pierre Hoo and Patrick Fumenier of Taj
  • Akio Takisaki The new tax treaty between Japan and France was signed on January 12 2007. The new treaty will become effective in 2007 by ratification and be applicable to the following taxes in Japan:
  • Companies already pay top dollar if they think they're buying the next big thing. But Claire Jones finds out that they could face even greater costs if they don't consider intellectual property tax issues
  • By Paolo Giacometti and Raul-Angelo Papotti of Chiomenti Studio Legale