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  • hannes-apr05.jpg
    McDermott Will & Emery partner becomes US head of IFA
    Steven Hannes started his two-year term as president of the International Fiscal Association's (IFA) US branch in February. Hannes was a member of the US branch's executive committee and was also an IFA vice-president for Washington D.C. For McDermott Will & Emery, Hannes advises on the tax aspects of cross-border transactions and tax controversy.
    March 31 2006
  • China added to the tax-treaty network
    On February 28 2006 a new tax treaty (Mexico's 31st) between Mexico and China was published in the Official Gazette and will became effective from January 1 2007.
    March 31 2006
  • Why Saudi Arabia is expanding its treaty network
    Observers of the Middle East region might have noticed the recent impetus by the Saudi Arabian government to improve its network of tax treaties. Saudi Arabia for a long time only had one tax treaty in place, with France. Over the last year, there has been a relative flurry of treaty negotiations leading to the recent signing of tax treaties with, amongst others, Russia, China, Malaysia, India, Pakistan and Italy.
    March 31 2006
  • How to defer tax on foreign spin-offs
    Non-Canadian corporations with a Canadian shareholder base planning to spin-off the shares of a non-Canadian subsidiary might wish to consider taking steps to provide their Canadian shareholders with the opportunity to elect to defer tax on the spin-off.
    March 31 2006
  • What legislative changes mean for taxpayers
    Changes to the French tax system in 2005 have significant implications for taxpayers concerning thin capitalization, VAT, shares acquisition and disputes, according to Ambroise Bricet, Sophie Chevance & Mathieu Gautier of Taj
    March 31 2006
  • Transfer pricing rules mark a turning point
    Transfer pricing has traditionally not been an issue for Spanish companies. Under existing legislation the burden of proof lies with the tax administration and there are not specific documentation requirements to be fulfilled by taxpayers.
    March 31 2006
  • Why the finance ministry withdrew the Fokus Bank appeal
    The Norwegian government has withdrawn its appeal to the Norwegian Supreme Court in the Fokus Bank case. Fokus Bank won its case before the Norwegian Appeal Court in May 2005 after the EFTA Court had given its opinion in case E-1/04 of November 23 2004 that the Norwegian withholding tax regime on dividends was conflicting with article 40 of the EEA Agreement (which mirrors article 56 of the EC Treaty).
    March 31 2006
  • What the ECJ's Halifax ruling means
    The European Court of Justice has recently given its ruling in the Halifax case. It stated that:
    March 31 2006
  • farkasdinardo-cm06.jpg
    US: Authorities learn from market on taxation of credit default swaps
    By Eva Farkas-DiNardo, Alston & Bird
    March 31 2006
  • Editorial
    The nature of M&A means transactions are likely to be cross-border and complex. Tax authorities in different jurisdictions do not always use the same criteria for the treatment of the same structure. That makes it imperative that international businesses receive world-class tax advice to help them through the task of dealing with the complex M&A tax rules that some countries have enacted.
    March 31 2006
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