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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
  • In a busy spring, the IRS has ruled on issues such as transfers of foreign stock and product grouping, and the courts have spoken on attorney-client privilege. Hal Hicks, David Benson and Marjorie Rollinson of Ernst & Young, Washington report on the latest developements
  • China has introduced tighter controls on processing trade activities to preserve tax revenue.
  • A tax reform in the UK Finance Bill threatens to harm the Eurobond market, lawyers are complaining. The Bill aims to close a loophole in the tax treatment of bonds redeemable at a premium over their issue price, but the lawyers worry that the reform extends beyond the loophole and will harm the tax treatment of standard bonds. The move comes while the UK government continues to campaign against the proposed EU withholding tax because of its claimed threat to the bond markets.
  • Norwegian firm Thomessen Krefting Greve Lund is advising Norsk Hydro, Norway's largest industrial conglomerate, on their offer to acquire Saga Petroleum, the third-largest oil company in Norway. Norsk Hydro have offered NKr 17.5 billion ($2.3 billion) for Saga. If the deal is completed Norsk will be the largest oil company in Norway after the state-owned Statoil.
  • Singapore’s minister of finance used this year’s budget to stimulate the economy by extending tax incentives for domestic companies and foreign investors alike. Ajit Prabhu of Deloitte & Touche, Singapore examines the budget and its consequences for multinationals
  • 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.
  • Ernst & Young in the UK and France is advising French minerals extraction and processing plant Imetal on its acquisition of English China Clays. The deal is worth £756 million ($1.2 billion).
  • General Electric Company (GEC) in the UK, is buying Fore Systems, an Internet equipment supplier-based in Pittsburgh for $4.5 billion. GEC has already agreed to sell its defence business to British Aerospace, and is now concentrating on building up its telecoms and internet capability. The acquisition follows GEC's purchase of US telecoms company Reltec.
  • Loan agreements – Stamp duty – Rules governing imposition – Discrimination.