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  • Revealing the uncertain consequences of cross-licensing agreements
    Treasury and the IRS have requested information regarding cross-licence agreements (CLA) in connection with an IRS project to provide guidance on the tax consequences of participating in a CLA.
    May 31 2006
  • Court rules on fringe benefits for expatriate employees
    The South African Income Tax Act contains a comprehensive set of provisions relating to the taxation of fringe benefits for employees. Not only are the benefits identified, but the legislation provides for an objective valuation mechanism to determine the quantum of the benefit to be taxed, as well as the reporting and collection mechanisms.
    May 31 2006
  • Why the country is best-placed for business headquarters
    Switzerland is a known and well-established location for regional or global headquarters of large international groups. Typically the decision to set up a regional headquarter is driven by the business need to operate cost effectively in highly competitive and saturated markets.
    May 31 2006
  • Bad-faith taxpayers defined
    To align the approach of the Russian court to the issue of abuse of tax legislation, the Supreme Arbitration Court prepared a draft informational letter that lists suspicious facts that are relevant to identification of bad faith taxpayers.
    May 31 2006
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    Big four battle it out
    Sed Crest reveals which firms have the best brands in tax in the 2006 client poll of tax services in Europe, Middle East and Africa
    May 31 2006
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    Solomon awaits Treasury confirmation
    President George W Bush's nomination of Eric Solomon as assistant secretary of the treasury for tax policy is expected to continue the simplification of the US tax code. Solomon, who is deputy assistant secretary for regulatory affairs and has been an important adviser to both the secretary of the treasury and the president since 1999, is expected to be ratified within the next three weeks.
    May 31 2006
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    What you should know about mining and taxation
    The importance of mining to the Canadian economy means taxpayers need to be well aware of every point where tax affects the industry, believe Michael Colborne and Terry Barnett of Thorsteinssons
    May 31 2006
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    Interview: New CIOT president speaks out on rule of law
    John Cullinane, the new leader of the UK's tax advisers, has taken on the task of boosting the standing of the profession and encouraging the government to stick to the rule of law in the tax system. He explains to Ralph Cunningham how he will achieve results
    May 31 2006
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    How Alcatel-Lucent and Daimler Chrysler mergers compare
    Kevin Rowe of Alston & Bird compares the Alcatel-Lucent merger with the DaimlerChrysler merger of 1998 and assesses how their structuring ensured tax-free status for each merger of "equals"
    May 31 2006
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    US reconciliation bill shakes up international tax provisions
    US tax practitioners believe that the new Subpart F look-through rule for interest, dividends, rents and royalties transferred between controlled foreign corporations (CFCs) will be very significant to US multinationals. The measure was contained in the Tax Increase Prevention and Reconciliation Act of 2005 (HR4297), signed by President George W Bush on May 17.
    May 31 2006
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