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  • The IRS recently issued Announcement 99-1, its long-anticipated proposal to update Revenue Procedure 65-17, which provides procedures for making adjustments to taxpayers' accounts to reflect the consequences of Internal Revenue Code section 482 transfer pricing adjustments.Revenue Procedure 65-17
  • Watson Farley promotes tax lawyer to top spot, Herkenroth swaps Andersen for Ashursts, Casino owners hit tax jackpot, Accountancy nerds knocked off blackspot, Driver eats evidence of unpalatable crime, Savory takes the softer option, Experience available: any takers?
  • The UK’s CFC regime is now 15 years old but ambiguities remain over which companies are affected. James Savory of Allen & Overy in London explains the system and comments on the consequences of the introduction of self assessment
  • China has introduced tighter controls on processing trade activities to preserve tax revenue.
  • Simpson Thacher & Bartlett is advising Bermuda telecoms company Global Crossing on it's acquisition of Global Marine.
  • Until recently, Ireland would not have been considered a favourable location for a holding company. This was because relatively high rates of tax were imposed on dividend income and capital gains, and because credit relief for foreign taxes suffered was quite limited. Since the enactment of its new corporate tax regime, a reduction in the rate of capital gains tax and amendments to the rules concerning credit relief for foreign taxes, however, the opportunities for using Ireland as a holding company location merits serious reconsideration by corporate treasurers when planning their international group structures.
  • Over the next two months, International Tax Review will publish a series of features examining CFC regimes around the world. Recent years have seen a rapid expansion of the scope of such regimes. Oliver Ralph reports on how multinationals are beginning to fight back
  • Ernst & Young acquires compliance firm, Tax probe reveals JAL discrepancies, Colombia extends banking tax, Brazil offers concessions to states, Venezuela offers tax breaks to oil investors, Japan reforms stock and bond tax, Mexico's maquilas fear tax change
  • Carter Ledyard & Milburn are advising UK group United News & Media on their acquisition of CMP Media, the US media group. United will add the Internet and print publishing businesses of CMP to its interests in PR Newswire and the UK's Channel 5 and other TV companies. The deal is worth $920 million. United News will pay $39 for each CMP share.
  • The Paris Office of Jones Day Reavis & Pogue is acting for Renault on their merger with Japanese company Nissan. The merger, which is valued at $5.4 billion, will create the fourth-biggest car maker in the world.