Search results for

Margie Rollingson, David Benson and Peg O'Connor of Ernst & Young analyze the Dow decision involving business purpose and corporate-owned life insurance where the court found in favour of the taxpayer

The US Senate ratified the Protocol to the US-Australia double tax agreement (DTA) on March 13 2003. Overall, the Protocol to the treaty is good for business between the two nations and the outcomes are positive. Among other things, it gives Australian companies with US subsidiaries level pegging for dividends with the UK, the most competitive US tax treaty in the world.

Guernsey is recommending introducing a withholding tax on EU resident individuals' savings interest instead of exchanging banking information when the EU tax package and Savings Directive is adopted.

Craig James - Integral Energy, Mark Tafft - Ernst & Young and Steve Vesperman - ATO:

An unfair dismissal lawsuit being brought against Levi Strauss by two former members of the company's tax group calls into doubt the company's tax and accounting practices.

Mukesh Butani of Ernst & Young looks at the likely impact of the proposed dividend taxation changes in India's Budget

Deloitte & Touche has announced that it is converting to a limited liability partnership (LLP) in the UK later this summer. In the post-Enron environment, protecting partners from as much risk as possible is vital for professional services firms, and becoming an LLP is increasingly popular. Deloitte is the last of the big four to convert and law firms are getting in on the act. But the much-desired international networks are proving to be problematic with authorities in some countries, such as France, threatening to tax income from a UK LLP as if it is from a company not a partnership.

In December 2002 the Special Commissioners published their decision in the case of Association of British Travel Agents Limited v Commissioners of Inland Revenue (Special Commissioners decision 359). The case concerned the application of the UK-controlled foreign companies (CFC) legislation in the context of two captive insurance companies.

Aforeign corporation that is engaged in a US trade or business is subject to regular US income tax on net income that is effectively connected with the trade or business. However, in order to claim deductions and credits otherwise available for calculating its US income tax liability, the foreign corporation must file a "timely and accurate" US income tax return. Failure to do so generally results in permanent disallowance of otherwise available deductions and credits. The IRS has recently issued regulations that significantly relax the standards for accepting late-filed tax returns.

On January 1 2003 Law 51/2002 entered into force (the Law) amending Spanish municipal taxation.