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  • IRS clarifies dividend distributions to non-resident alien individuals
    In a taxpayer-friendly interpretation of new rules on regulated investment company (RIC) dividends received by non-resident aliens, Revenue Ruling 2005-31 (2005-21 I.R.B. 1) holds that a RIC may designate the maximum amount permitted in respect of its distributions as qualified dividends, capital-gain dividends, short-term capital gain dividends and interest-related dividends even if the designations cause inconsistent reporting of the RIC's income by its US shareholders and non-resident alien shareholders.
    June 30 2005
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    Using unspecified methods: don't panic
    By Anne Welsh, Patricia Fouts and Sean Foley (all US)
    June 30 2005
  • Finance Act 2005 restricts double-taxation relief
    Two changes have been introduced restricting the credit the UK Revenue will permit for foreign tax paid on foreign income. They are:
    June 30 2005
  • Proposed amendments to the thin-capitalization rules
    Article 269.2 of the Russian Tax Code provides for thin-capitalization rules that apply only to loans received by a Russian company from a foreign entity that directly or indirectly owns more than 20% of its share capital. The maximum deduction on such loans is calculated based on a debt-to-equity ratio of 3:1 (12.5:1 for banks). Any interest paid on debt exceeding this ratio is reclassified as a dividend, and therefore:
    June 30 2005
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    Multiple-year data: divergent views
    François Vincent (Canada), Bob Alltop (US), Stéphane Dupuis (Canada)
    June 30 2005
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    Comparables: geographic market and other factors
    By Steve Fortier (US), Geoff Soh (Singapore) and Dirk Van Stappen (Belgium)
    June 30 2005
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    Meeting the "contemporaneous" requirement: a practical guide
    By Sean Foley (US) and Andrew Hickman (UK)
    June 30 2005
  • boykin-holdingcompanies05.jpg
    Introduction
    By Dick Boykin (US), Steve Fortier (US), Masanori Kawanobe (Japan), Dan Peters (US) and Dave Rutges (Netherlands)
    June 30 2005
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    European cases deal with critical issues for financial sector
    By Barry Larking (Netherlands), Christian Amand (Belgium), Paul Stewart (UK) and Vincent Dielwart (Netherlands)
    June 30 2005
  • Deloitte boosts UK tax controversy team
    Deloitte has hired two high-profile tax specialists to boost its UK tax controversy team. Sue Holmes, a former tax inspector at the UK Inland Revenue, joined the big-four firm to lead its London tax risk and resolution practice and Gary Brothers, a former tax investigator at HM Revenue & Customs joined Deloitte's Leeds office.
    June 30 2005
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