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Deals of the year 2003

The tax lawyers involved in the most innovative transactions of the last year comment on how they were put together

March 01 2004

Changes to partnership losses hit UK film industry

The UK Inland Revenue launched a surprise attack on relief for trading losses through partnerships last week. Although the February 10 announcement did not specifically mention the film industry, which the government has repeatedly pledged to support with tax incentives, funding for many UK films was jeopardized.

March 01 2004

Arthur Cox poaches Linklaters tax partner

Former Linklaters senior tax partner Conor Hurley switched to Irish law firm Arthur Cox on March 1 2004. Hurley advises clients on international corporate taxation and specializes in the tax aspects of cross-border mergers and acquisitions, banking, capital markets and structured finance. He was also head of the investment funds tax practice at Linklaters' London office.

March 01 2004

Sarbanes Oxley drives transfer pricing moves

Strong demand for transfer pricing services post-Sarbanes-Oxley legislation in the US continues to stir the delivery of such services, with another transfer pricing boutique springing up.

March 01 2004

Ending the extraterritorial-income-tax regime

It may be the beginning of the end for the 30-year battle over the extraterritorial-income-tax regime (ETI) and its predecessors. Under ETI, US exporters may exclude from taxable income a portion of their overseas sales. In January 2002, the World Trade Organization (WTO) confirmed its ruling declaring that ETI is a prohibited export subsidy. This followed the WTO's earlier ruling striking down the similar US foreign-sales-corporation (FSC) regime.

March 01 2004

Decree makes tax treatment of funds transparent

A new decree allows non-German investors to invest in a German limited partnership without paying German income tax, but tax on carried interest remains. Dietgard Klingberg and Lars Lawall of PricewaterhouseCoopers explain

March 01 2004

Bush Budget to reform international tax

The Bush Administration's 2005 Budget proposal and the Treasury's so-called Blue Book (General Explanations of the Administration's Fiscal Year 2005 Revenue Proposals), both published in early February, seek to reform US international tax law in a number of ways.

March 01 2004

UK Crown dependencies cut corporate tax rates

Governments in the Isle of Man and the Channel Islands are moving towards 0% rates of corporate tax in response to EU and OECD pressure on harmful tax practices and to compete with each other for essential foreign direct investment.

March 01 2004

Limits on foreign companies' interest expense

Under standard provisions in US income tax treaties, a foreign company that is conducting business in the US through a branch is subject to regular US income tax on its US income attributable to a permanent establishment (PE) maintained in the US. Under Treasury Regulation section 1.882-5, in determining the branch's taxable income, interest expense for the US branch is determined by apportioning the taxpayer's worldwide interest expense under a three-step apportionment formula.

March 01 2004

De Brauw lures lawyers from Freshfields' Dutch tax team

Dutch law firm De Brauw Blackstone Westbroek confirmed the hire of tax specialists Dick Hofland and Paul Sleurink on February 19 2004. Hofland, formerly at Freshfields Bruckhaus Deringer, specializes in international tax law with an emphasis on mergers and acquisitions and corporate tax planning. Sleurink joins the firm from Merrill Lynch in London and focuses on the tax aspects of structured finance and equity-linked products. The pair will be based in the Amsterdam office.

March 01 2004

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