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  • Clear Channel asked Texas-based Akin, Gump, Strauss, Hauer & Feld to act on the deal, with partner W Thomas Weir and associate Scott Stewart providing tax advice.
  • The revenue authorities in Mumbai had previously disallowed a number of benefits of the tax treaty between India and Mauritius to certain investment funds based in Mauritius, on the basis that these entities were established in Mauritius purely for the avoidance of Indian taxes and for treaty shopping. This conclusion was reached based on an analysis of the operating structure of the relevant Mauritius-based funds.
  • land's Finance Act 2000 has fundamentally changed the tax treatment of funds in Ireland. It attempts to homogenize the tax treatment between investment funds previously available to Irish residents (domestic funds) and those which were only available to non-Irish residents. In so doing, the new regime deals with some EU concerns and especially Spanish discontent at the alleged discriminatory treatment of the previous regime. The changes should further enhance Ireland's attractiveness as a base from which to conduct investment fund business and provide Irish investors with a new attractive investment vehicle.
  • Opportunity to be creative attracts new recruit Dolan
  • Australia is now at the mid-point in what purports to be the total overhaul of its direct and indirect tax system. Peter McCullough of Deloitte Touche Tohmatsu, Australia and Ali Noroozi of Linklaters, UK detail the proposed changes
  • A high court of appeal decision in the UK could open the floodgates for insurance companies wanting to reclaim value-added tax (VAT) payments.
  • On February 3 2000, the Second Chamber of the Dutch Parliament adopted two bills relating to the new 2001 Personal Income Tax Act and amendments to several other tax acts. Amendments have been made to these bills on several points since they were initially proposed on September 14 1999.
  • In what many view as a rather surprising decision, Canada's Federal Court of Appeals (FCA) recently ruled that a US consultant did not have a fixed base (ie taxable presence) in Canada. Under article 14 of the Canada-US treaty, and any other OECD-based treaty, a host country does not tax an independent contractor unless he or she works from a fixed base. The same guidelines determine whether the presence of a US company's employees in Canada creates a permanent establishment, which is defined as a fixed place of business through which the business of an enterprise is wholly or partly carried on.
  • The biggest surprise in the UK’s 2000 budget came in the form of the abolition of offshore mixers. This is just one aspect of a toughening of the Inland Revenue’s stance across the board. Helen Lethaby and Susan Bell of Freshfields, London outline the aggressive new regime
  • A call to PricewaterhouseCooper's office in Singapore reveals the true breadth of the firm's client services. Having phoned PwC's listed number, International Tax Review was intrigued to discover that it had reached White Express, a downtown laundry service.