Search results for

On June 13 2002, just one day after approval by the Brazilian Congress, President Fernando Henrique Cardoso signed an amendment to the Brazilian Constitution. As set out under Constitutional Amendment Number 37, the application of the temporary contribution on financial activities (CPMF) was extended until December 31 2004. The CPMF was first created in 1997 as a temporary tax on financial transactions and is charged on every debit (a withdrawal or transfer for example) from a bank account. The following CPMF rates apply until the end of 2004:

As the EU gets serious about tax harmonization, investors need to give serious consideration to alternative tax scenarios. By S Alan Hamburger, Morgan Lewis & Bockius, Brussels

The Supreme Court agrees to review the Boeing decision, a new information agreement is signed with Netherlands Antilles, and the IRS denies APAs to check-the-box taxpayers. By Hal Hicks, David Benson and Peg O'Conner, Ernst & Young, Washington

655 Fifteenth Street, NW, Suite 900

1301 McKinney, Suite 5100

A recent decision by Germany's highest tax court revises the interpretation of section 160 of the German Tax Procedure Act (AO or Abgabenordnung) as it applies to mailbox companies resident within the EU.

The Paris Administrative Lower Court held in a recent decision (June 26 2001, Société Janfin), that tax credits (avoirs fiscaux) attached to French dividends could not be used to pay French corporate income tax when a company purchased shares only to use the tax credits attached to dividends, and resold these shares to their original owner immediately after receiving the dividends and tax credits.

Investors in Japan have a variety of new rules at their disposal for setting up share-for-share exchanges and corporate restructuring. Take full advantage, urge Todd M Landau and Shinji Ishiguro of PricewaterhouseCoopers, New York and Tokyo

Indian Finance Minister, Jaswant Singh has refused to initiate a review of the existing India-Mauritius tax treaty. Critics of the treaty argue that in its present form it is being misused by Indian businesses. At the moment Indian companies or individuals are able to set up a Mauritian company and make investments into India while under the double tax treaty capital gains tax is only payable in one country. This has been used by companies to avoid paying capital gains tax on investments in India and in 2000 was branded abuse of the treaty by tax inspectors.

A US tax bill aiming to improve international competitiveness and simplify the complicated US tax system could hit foreign investment into the country. The bill, proposed by the chair of the ways and means committee, suggests a comprehensive tax overhaul.