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  • The US Internal Revenue Code section 6031(e) exempts foreign partnerships that have no income from US sources, or are effectively connected with a US trade or business, from filing a partnership tax return even if they have US partners. This little-noticed provision of the Taxpayer Relief Act 1997 (TRA 1997) was intended to bring to an end years of uncertainty about the US filing obligations of foreign partnerships. Proposed regulations issued on January 23 1998 expand the filing exemption and provide other filing reliefs to foreign partnerships.
  • In late 1997, the tax authorities released a new directive clarifying their views on the value-added tax (VAT) treatment of telecommunications and tele-services. As expected, the directive provides that tele-services are not identical to telecoms services, and hence are potentially subject to different VAT treatment.
  • Import exemptions relating to customs duty and value-added tax (VAT) were reintroduced on January 1 1998, following their abolition in April 1996. However, only a relatively small group of foreign investors will now qualify for the exemptions.
  • The 1998 Mexican tax reforms, published in the Official Gazette on December 29 1997, contain important transfer pricing amendments, and amendments to the rules relating to the taxation of derivative transactions, back-to-back loan arrangements, and investments in low-tax jurisdictions.
  • A new decision on "turbo funds" sheds new light on the scope of the sham transaction procedure, as well as on the way the 80% penalty attached should apply (Tribunal Administratif d'Orleans – 1ère Chambre, December 9 1997 – req no 95-1535 – Société SDMO)
  • Legislation to implement provisions to counter franking credit trading and dividend streaming was introduced into parliament on December 4 1997. There has been considerable discussion about the proposed rules, which will be debated in parliament during March/April 1998. The rules apply to dividends and other distributions paid on or after 7.30pm, May 13 1997.
  • Canada's government unveiled its new budget on February 24. Many measures modify international aspects of Canada's tax system and will generally apply after the 1997 taxation year.
  • Argentina's Executive has announced a package of fiscal measures, which will be submitted to Congress for approval.
  • In the first part of International Tax Review’s survey of oil and gas tax regimes, Vibe Amundsen and Ian Sutherland of Ernst & Young, Oslo and Calgary highlight essential information for investors in Norway and Canada
  • Singapore has introduced a budget designed to reinforce the country’s role as a prime location for financial services and logistics. Chris Kinsella of Coopers & Lybrand, Singapore reports on the specific measures and their impact