Search results for

Legal updates have altered the tax environment for the booming real estate market, reports Carlo Galli of Maisto e Associati

Tax reform may be needed to abolish taxes that are distorting the economy, report Andrés Edelstein and Gustavo Wunder of PricewaterhouseCoopers

Welcome to this Argentina special feature in the November 2006 issue of International Tax Review.

Henry An Jin-Young (David) Lee On August 21, the Ministry of Finance & Economy (MOFE) announced its proposed tax reforms. After consulting with various government ministries to finalize the proposals, MOFE will submit the proposals to the National Assembly in October for approval. If approved, the proposed changes will generally become effective from January 2007.

Carlos Casanovas, Gustavo Scravaglieri and Ariel Becher of Ernst & Young discuss how the country's thin-capitalization rules affect interest payments to foreign related parties

Marina Capel, head of tax of Reuters Asia calls for multilateral improvements to tax administration in Asia

No imminent changes to the Internal Revenue Code may be good for the rest of us, believes Chris Wales

With its acquisition of competitor GN Resound, Phonak will become the world's largest hearing aid manufacturer. Claire Jones found out how an unusual structuring ensured a low tax cost

Jack Cummings Kevin Rowe Notice 2006-85 shuts down a scheme that the IRS apparently has known about for some time by which controlled foreign corporations (CFC) or US subsidiaries of foreign parents can repatriate earnings without US tax to the parent through the triangular reorganization rules. Basically the idea is that the CFC or the subsidiary uses the parent stock in a triangular reorganization, but pays the parent for the stock rather than receiving it as a contribution to capital. The payment is received by the parent tax-free under Internal Revenue Code section 1032, or at least it arguably was received tax free before the Notice.

Barbara Brauchli Rohrer Marcel Widrig The deadline for a referendum in respect of the Federal Law on Urgent Adjustments to Corporate Taxation expired unused on October 12 2006. As a result, as of January 1 2007 (federal tax) and January 1 2008 (cantonal tax), new rules will be applicable to indirect partial liquidation cases and so-called transposition cases.