ITR Search | International Tax Review

US case law: the rulings that count

In a busy year, the US tax courts ruled on subjects ranging from foreign tax credits to related party borrowings. Daniel Berman and Jeffrey Korenblatt, Sutherland Asbill & Brennan LLP, Washington DC analyze the rulings and their consequences

March 31 1999

Centros Ltd and Erhvervs-og Selskabsstyrelsen

Freedom of establishment – Establishment of a branch by a company not carrying on any actual business – Circumvention of national law – Refusal to register.

March 09 1999

Russian Tax Code

Part I of the Russian Tax Code became effective on January 1 1999. It introduced a number of developments in personal income tax legislation, which will affect expatriates working in Russia as well as local staff. The main provisions are outlined below, but it should be noted that the legislation is probably more remarkable for what it did not include.

March 01 1999

The vis attractiva

The use of the so-called vis attractiva (literally power of attraction) highlights the link between the concepts of income and residence. It might be used to attribute foreign income profits to substantially Italian tax resident individuals who are formally resident abroad.

March 01 1999

Publication of Finance Bill 1999

Ireland's minister for finance has published his Finance Bill which runs to a weighty 326 pages. The following are some of the principle features outlined in the Finance Bill.

March 01 1999

Back to the drawing board for Canada?

Proposals to reform Canada’s interest imputation rule have provoked debate. Elinore Richardson and Angelo Nikolakakis of Stikeman, Elliott, Montreal and Toronto examine the proposals and outline the arguments against their unqualified adoption

March 01 1999

Vietnam turns up the fiscal temperature

A recent circular from Vietnam’s Ministry of Finance has introduced extensive regulations for foreign investment. Tony Foster of Freshfields in Hanoi examines the consequences for multinationals who must now adopt Vietnamese accounting principles

March 01 1999

Clinton stuns with tough budget

Bill Clinton’s latest budget includes numerous international tax proposals and tax shelter provisions. Hal Hicks, David Benson, Margie Rollinson, and Peg O’Connor of Ernst & Young in Washington DC analyze the budget, and explain court and treaty developments

March 01 1999

Ernst & Young scoops leading Canadian lawyer

They’ve done it again. Less than two years after recruiting Robert Couzin from Stikeman, Elliott, the Canadian office of Ernst & Young has swiped another leading tax partner from a law firm. This time the partner in question is Ron Sirkis who until this month was head of tax at Bennett Jones Verchere.

March 01 1999

News in Brief

Bond market fails to win exemption, Manx Treasury reveals 15% company tax, Indonesia gives tax breaks to revive economy, Loss of revenue reveals Japanese troubles

March 01 1999

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