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  • New reasonable-expectation-of-profit rule
    Proposed amendments to the Income Tax Act (Canada), released on October 31 2003, will have a significant impact on planning and structuring for the acquisition of businesses and properties in Canada. The draft proposals will be the subject of "extensive consultations" but, if enacted, will be applicable for taxation years beginning after 2004 with no grandfathering for existing structures.
    February 01 2004
  • Tax consolidation - the monster clean up
    The government delivered an early Christmas present for business when it delivered on some of their concerns by renovating the new tax consolidation regime to tailor it more closely to their needs.
    February 01 2004
  • archinto-feb04.jpg
    Brazil slashes excise tax on capital goods
    Jayme Archinto: The cut may be controversial President Luiz Inacio Lula da Silva signed a Decree on January 15 2004, cutting excise tax on capital goods, including machinery and equipment by up to 33%. The Decree reduces the excise tax on industrialized products, imported or local, for 643 capital goods.
    February 01 2004
  • Spain offers tax-friendly Tier One products
    Spain has introduced a new tax and regulatory regime to deal with foreign capital movement. Carlos Albiñana of Allen & Overy believes the law could be strengthened
    February 01 2004
  • UN calls for new international tax body
    A UN meeting of tax experts has proposed setting up a new body covering international tax called the UN Fiscal Committee.
    February 01 2004
  • A&O tops up tax team in Italy
    UK magic-circle law firm Allen & Overy (A&O) has taken over a top Italian tax boutique to boost its European tax practice in Milan and Rome. Andrea Manganelli and Francesco Parisi, co-founders of Andrea Manganelli e Associati, joined A&O as partners on January 29 2004 and brought 15 tax associates with them. A&O also hired Quirino Imbimbo as of counsel in the Milan office.
    February 01 2004
  • KPMG announces new senior appointments
    On January 28 2004 James Brasher was named vice chair of tax services at KPMG in New York. At the same time John Chopak was made vice chair of tax services operations. The management changes are aimed at inspiring confidence in the integrity of KPMG's tax services after investigations in the US into so-called abusive tax shelters.
    February 01 2004
  • UK law firms slapped with one-off tax bill
    A change in accounting standards will slap a one-off tax bill on UK law firms that could run into millions of pounds. From the beginning of 2004 law firms will have to account for work in progress at the billable value rather than cost, making taxable profits much higher.
    February 01 2004
  • Dezzani starts new tax practice in Milan
    Former Zini & Associates tax partner Luca Dezzani has left the firm, taking four members of the tax team with him
    February 01 2004
  • US Inbound update: Pricing related-party services
    The proposed section 482 services regulations change many aspects of the transfer pricing regulations for related-party services and the ownership of intangible property
    February 01 2004
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