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  • ELIMINATION OF FRENCH BRANCH TAX FOR EU COMPANIES
    By virtue of article 115 quinquies of the French tax code, after-tax profits realized by foreign companies in France (especially through a French branch) are deemed to be distributed to non-French tax resident partners, and are subject to a 25% branch tax (with possible limitation or exemption, depending on the applicable tax treaty).
    March 01 1998
  • The Taxation of Intangibles (Special supplement): Japan
    A special report prepared by Jonathan Stuart-Smith and Tomohiko Kaneko of Deloitte Touche Tohmatsu, Tokyo
    March 01 1998
  • Expatriate taxation in Europe Survey Part three: The discreet charms of expat tax
    Italy, Spain, Sweden and Switzerland are not celebrated expatriate tax locations, but as the third and final part of this survey shows, they offer some hidden attractions, some planning opportunities, and present some pitfalls to watch out for
    March 01 1998
  • US position raises new questions
    A new provision and temporary regulations should simplify the complex issues relating to passive foreign investment companies. Unfortunately, the rules inadequately address key issues. By Dale Collinson and Patrick Carmody of Willkie, Farr & Gallagher in New York
    March 01 1998
  • SPANISH LEGAL ENTITIES AS HYBRIDS FOR US TAX PURPOSES
    The entry into force in the US, on January 1 1997, of the IRS's final regulations under Section 301.7701 of the Internal Revenue Code (the so-called check-the-box regulations) requires a new analysis of the classification of Spanish legal entities.
    March 01 1998
  • SHORT-TERM DEBT EXCEPTION TO THIN-CAPITALIZATION RULES
    A recent tax court decision raises the possibility that an important new exception may be emerging in the complex statutory thin-capitalization rules which have been in force in Germany since 1994.
    March 01 1998
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    Striking a good deal in Japan
    Japan now offers foreign investors a warm welcome, and a range of acquisition opportunities. Dean Yoost and Todd Landau of Coopers & Lybrand in Tokyo and New York present a tax guide to structuring acquisitions in Japan
    March 01 1998
  • BELGIUM AND THE NETHERLANDS REMOVED FROM THE WHITE LIST
    Under Finland's legislation on the Taxation of Shareholders of Foreign Intermediate Companies (the Act), resident taxpayers in Finland must notify the Finnish tax authorities of their holdings in foreign companies. The resident taxpayers are liable to pay tax on their share of the profits of such companies in accordance with certain conditions.
    March 01 1998
  • Holding competition hots up
    A comparative approach is adopted in this assessment of Italy’s realistic potential as a holding company location. By Piergiorgio Valente and Marco Magenta, Studio Associato Legale Tributario (associated with Ernst & Young International), Milan
    March 01 1998
  • CANADA CROSSES THE BORDER
    As part of its April 26 1995 technical bill of proposed amendments to the Canadian Federal Income Tax Act, Canada's Department of Finance released sweeping changes to the definition of, and rules relating to, the concept of taxable Canadian property (TCP).
    March 01 1998
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