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Weil, Gotshal & Manges has been assisting Morgan Stanley on the introduction of Eurocredit, a Euro416.5 million ($436.3 million) collateralized debt obligation.

Directive 69/335/EEC — Indirect taxes on the raising of capital — Charge for drawing up a notarially attested act recording an increase in share capital and a change in a company's name and registered office.

Freedom of establishment — Taxes on companies’ income — Tax concessions.

Directive 78/660/EEC — Annual accounts — Principle of a true and fair view — Principle that valuations must be made on a prudent basis — Principle that valuations must be made separately — Global provisions for a number of potential liabilities — Conditions governing the making of provisions.

Whether a duty imposed on the capitalisation of undistributed, but previously taxed, profits of a capital company constitutes a capital duty prohibited by Council Directive 69/335/EEC, as amended by Council Directive 85/303/EEC.

China’s efforts to boost new technology could have welcome consequences for foreign investors. Elizabeth Thong of Simmons & Simmons in Shanghai explains how multinationals can benefit from the latest incentives

The German CFC regime was, like many others, founded on the principles of the US’ Subpart F. Since its inception in 1972, the rules have been adapted to focus on capital investments. Mark Smith and Diether Laudan of Ernst & Young in Stuttgart explain the rules

After a string of victories in the US tax courts, the IRS has lost a transfer pricing case. Not only did Compaq (the company concerned) avoid the excess tax that the IRS had charged, but they also received a positive adjustment of $21 million. This is the first time in a reported case that a company has received a positive adjustment.

When Japan lifted its restriction on holding companies last year, it opened up a range of possibilities. Dean Yoost of PricewaterhouseCoopers and Masaakira Kitazawa of Anderson Mori advise on how to avoid the pitfalls and make the most of the new opportunities

On July 9 1999, the Treasury formally withdrew the proposed and temporary regulations issued on March 23 1998, relating to the use of hybrid branch entities to avoid subpart F income. At the same time, the Treasury issued new proposed regulations on the treatment of hybrid branch transactions. The Treasury also officially withdrew the proposed regulations relating to the treatment of foreign partnerships for purposes of subpart F (Brown Group regulations) but did not issue any new regulations in their place. New regulations regarding the treatment of a controlled foreign corporation's (CFC) distributive share of partnership income will be proposed at a later date.