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There are 33,124 results that match your search.33,124 results
  • macdonald-may05.jpg
    French law firm sets up US tax practice
    Robert MacDonald: Switched firms after listening to a headhunter Gide Loyrette Nouel, a French international law firm, has started a US tax practice with the hire of Robert MacDonald in its New York office.
    May 04 2005
  • New anti-inversion provision has broad reach
    The American Jobs Creation Act of 2004 added Internal Revenue Code section 7874 to the code to combat the perceived abuse of inversions of US corporations into foreign corporations. The provision is overly broad and in its current form may result in significant adverse income tax consequences to many internal restructurings within an affiliated group of corporations.
    May 04 2005
  • Getting the most out of the double tax treaty with Cyprus
    Under the double tax treaty with Cyprus, investors can enjoy a 5% withholding tax rate on dividends distributed by a Russian subsidiary, rather than the regular 15% rate. Therefore, using Cypriot holding companies is one of the most typical vehicles to structure inbound investments in Russia.
    May 04 2005
  • Tax treaty network expanding
    As part of the government's efforts to increase the number of countries with whom Oman has comprehensive double taxation avoidance treaties, Oman recently signed a treaty with Iran.
    May 04 2005
  • craig-may05.jpg
    M&S opinion keeps Europe guessing
    The opinion of the advocate-general in the Marks & Spencer (M&S) case at the European Court of Justice (ECJ) backs up the UK retailer's argument for cross-border group relief within the EU. But confusion remains about how the opinion will shape the final judgment and how national governments will react. Ralph Cunningham and Simon Briault investigate
    May 04 2005
  • Budget 2005 - Avoidance through arbitrage
    At the time of the Budget, the HM Revenue and Customs announced a proposal to counter tax avoidance using arbitrage schemes that involve hybrid entities or hybrid instruments. The intention behind the proposed legislation is that it should apply where an arbitrage scheme using a hybrid entity or instrument results in:
    May 04 2005
  • mcdermottwe-may05.jpg
    Law firms expand German tax teams
    Oliver Kächele, Markus Roth and Joachim Giehl Baker & McKenzie, McDermott Will & Emery and Haarmann Hemmelrath have all expanded their tax practices in Germany by hiring tax specialists from accounting firms.
    May 04 2005
  • How the new thin-capitalization rules work
    The two ECJ judgments Lankhorst-Hohorst and Bosal Holding are causing thin-capitalization changes in Polish corporate tax. In 1999 thin-capitalization rules were introduced into the Polish tax system. These rules used to cover loans and credit provided by shareholders - Polish tax residents as well as non-residents.
    May 04 2005
  • A new tax credit for training expenses
    Anew tax system for training expenses was introduced on April 1. The new system allows a corporation to credit the amount of training expenditure against its corporate tax. The limitation of the credit is 10% of the corporate tax.
    May 04 2005
  • Advocate general rules regional tax contravenes VAT Directive
    An advocate general opinion of the European Court of Justice (ECJ) exposes inconsistencies between the regional tax on productive activities (IRAP) and the VAT Directive.
    May 04 2005
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