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Foreign investments in Spanish real estate have increased considerably in the past few years, requiring proper tax planning. José Maria Cusí and Carmen Gómez de Cadiñanos of Clifford Chance reveal how to do it tax-efficiently

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Companies will soon need to adjust to new rules governing the utilization and creation of revenue losses, if legislation currently before parliament is enacted. The changes are largely beneficial to companies and are proposed to apply from the income year in which July 1 2002 falls.

As announced in our April 2003 international update, the Swiss federal tax authorities have issued on May 6 2003 an information letter (Rundschreiben) regarding taxation of stock options in Switzerland. This letter has a significant impact on the tax treatment of stock option plans in Switzerland. We believe that it is important to analyze the impact in detail for the issuing company and the individuals receiving stock options, as there are significant potential tax and social security saving opportunities.

The Tax Department is currently made up by six partners and five senior associates, assisted by around 20 other tax lawyers from the offices of Madrid, Barcelona, Valencia, New York, Lisbon and Sao Paulo. The Department advises on all Spanish, Portuguese and Brazilian direct and indirect taxes, but has particular expertise in mergers and acquisitions, financial products and capital markets, international tax planning, real estate transactions and project finance, assurance and pension funds and tax investigation and disputes.

Otto-Hans Nowak and Grant J Russell of Borden Ladner Gervais analyze how the Canadian government has amended its proposed scheme for non-resident trusts

Hal Hicks: An opportunity he could not turn down The US Internal Revenue Service (IRS) has taken in a host of new talent, drawing key names from the private sector to boost its capabilities.

Dave Rutges, Eduard Sporken and Miodrag Verwoert of KPMG Meijburg & Co investigate how advance pricing agreement practice has changed in the Netherlands

According to the reform enacted through Law number 25,585 (published in the Official Bulletin on May 15 2002) foreign investors are subject to the personal assets tax on their participation in local companies. Decree 988 (published in the Official Bulletin on April 29 2003) clarified many aspects of the new tax.

The use of domestic reverse hybrids in cross-border financing continues despite the issuance by the Internal Revenue Service (IRS) of regulations designed to shut down abuses in the area. These devices, if structured correctly, may enable taxpayers to enjoy double-dip tax benefits with respect to interest expense and reduced withholding under US income tax treaties.