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  • Why the sandwich structure problem needs innovative solutions
    A recent IRS ruling (PLR 200532036) illustrates one solution to problems stemming from the all-too-common occurrence of a so-called sandwich in a cross-border holding company structure. The solution did not eliminate the sandwich, but used a section 355 spin-off to enable a foreign shareholder to claim an indirect foreign tax credit for taxes paid by a foreign subsidiary owned by the foreign shareholder's US consolidated group.
    November 01 2005
  • Why withholding taxes are under threat
    These are indeed troubled times for governments that rely heavily on withholding taxes for revenue. After Fokusbank decided by the European Free Trade Area (EFTA) court (E-1/104) and the pending case Denkavit (C-170/05), more and more decisions can be expected from local judges questioning the right of withholding in cross-border situations.
    November 01 2005
  • Income tax law changes
    Due to an extremely low tax threshold, China has created a rapidly growing group of citizens subject to personal income tax in the past years.
    November 01 2005
  • Kodak takes tax hit
    A $900 million tax charge contributed to Eastman Kodak posting a fourth-quarter loss of $1.03 billion in October. This was directly related to the firm's attempts to become a digital products and printing service provider.
    November 01 2005
  • Russian tax official arrested for accepting $1 million bribe
    The deputy head of the tax service's banking department has been arrested by the FSB security police on a charge of demanding $1 million from the chairman of a Moscow bank to reduce the bank's tax bill.
    November 01 2005
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    Court referral puts Emag issues in spotlight
    The Emag VAT case gives the European Court of Justice the opportunity to offer fresh thinking on the concept of "static" and "moving" supplies as a tool for analyzing chain transactions, point out Henry Cairns-Terry and Simon Kirk of Ernst & Young
    November 01 2005
  • IRS provides safe harbours for certain reorganizations subject to section 367(a)
    Taxpayers transferring assets to a foreign corporation are required, under certain circumstances, to file a gain recognition agreement (GRA) in conjunction with the transfer. GRAs are generally required to obtain tax-free treatment for certain outbound transfers of corporate stock and securities subject to section 367(a). See Treasury Regulation section 1.367(a)-3.
    November 01 2005
  • The new national insurance contributions Bill
    The UK government continues to focus on tax avoidance. The government has published a new national insurance contributions Bill that is aimed at combating avoidance.
    November 01 2005
  • Court verdict on the Sixth Directive trumps domestic law
    On October 12 2005 the Administrative Court in Warsaw issued a precedential verdict on the taxpayer's right to directly apply provisions of the Sixth Directive in a case where national legislation are contradictory to the relevant regulations of that Directive.
    November 01 2005
  • What the US-Mexico agreement on partnerships means
    The tax treatment of some so-called flow-through entities (S Corporations and limited liability companies or LLCs for example) has been always an issue under the Mexico – US tax treaty. As it stands now, under a protocol to the treaty, a partnership, state or trust is a resident of a contracting state only to the extent that the income it derives is subject to tax in that state, as the income of a resident, either through the partnership, state or trust or its partners or beneficiaries.
    November 01 2005
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