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Baker & McKenzie

December 01 2005

Chiltern hires investigations chief

John O'Donnell: Objective to develop assets confiscation practice John O'Donnell, previously a senior manager with PricewaterhouseCoopers tax investigations practice, has joined UK tax consultancy firm, Chiltern.

December 01 2005

Why foreign control groups can deduct excess employee compensation

The IRS has ruled that section 162(m) of the Internal Revenue Code, on disallowance of deductions for excessive compensation, does not apply to US subsidiaries of publicly held foreign corporations.

December 01 2005

How Spanish law could be discriminating against EU shareholders

Under the Spanish Corporate Income Tax Law, Spanish-source dividends received by Spanish resident corporate shareholders who have held, directly or indirectly, at least 5% of the paid-in capital of the company for at least one year, trigger a tax credit amounting to 100% of the tax liability arising from said dividends. In practice, this has the same result as an exemption and fully avoids economic double taxation.

December 01 2005

Court considers reasonable measures to avoid withholding tax on bond issues

A recent case, IndoFood International v J P Morgan Chase, considered what constituted "reasonable measures" in the context of a clause that allowed an issuer of loan notes to redeem those loan notes where an additional tax charge was imposed if the withholding obligation could not be avoided by the issuer taking reasonable measures available to it.

December 01 2005

Local firms gain market share in Latin America

Sed Crest finds out which firm has the best brand in Latin America and that tax advisers need to think like their clients

December 01 2005

IRS tests new arm's-length and cost sharing theories in Tax Court

James Fuller, Kenneth Clark, and William Colgin, Jr of Fenwick & West trace the emergence of the IRS' arguments in the Xilinx case, and the role of the new theories on cost sharing in the 2003 final regulations and the 2005 proposed regulations

December 01 2005

Tax authorities take on the treaty shoppers

Jeffrey Trossman and Amanda Heale of Blake, Cassels & Graydon discuss how the Canada Revenue Agency is challenging transactions that seek to benefit from treaty shopping and analyze the approach of the courts on the issue

December 01 2005

Tax strategies for Germany after the election

All large political parties in Germany agree that significant tax reform is necessary. Christian Ehlermann and Christoph Röper of Deloitte discuss whether the new coalition government can pull off reform and reassure international investors

December 01 2005

Profit split methods: Intangibles, market structure and the use of profit split methods

By Emmanuel Llinares, NERA Economic Consulting

December 01 2005

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