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  • Decisions of the highest courts significantly reduce corporate tax burdens
    Supreme Court overrules legality of certain tax resolutions passed by the Kirienko government
    December 01 1998
  • New case law eases the use of tax losses
    Tax losses are normally carried forward on the profits of the following five years (except for losses derived from the depreciation of fixed assets), unless the tax paying entity elects to carry-back its tax losses on its profits made during the preceding three years.
    December 01 1998
  • Collective investment offshore funds; Cyprus double tax treaty with Russia
    Collective investment funds or mutual funds have been around for a long time. They offer the opportunity to investors, large and small, who may or may not be acquainted with investment techniques, to pool their funds with the primary aim of spreading their investment risk and obtaining stronger purchasing power. A collective investment fund can either be a close-ended or open-ended fund.
    December 01 1998
  • General Electric and Lockheed Martin tax-free exchange
    General Electric and Lockheed Martin have agreed to a tax-free exchange. General Electric will exchange its holding of Lockheed Martin preferred stock, and some non-core businesses, in return for a wholly-owned subsidiary of Lockheed Martin. The subsidiary owns Access Graphics, LM Aerostructures, and an equity stake in telecommunications service provider, Globalstar.
    December 01 1998
  • Draft revision of Swiss unilateral tax treaty abuse decree lowers restrictions for active and quoted companies as well as for pension funds
    Switzerland has concluded tax treaties with well over 40 countries. The majority of the treaties do not contain specific treaty abuse provisions, a fact which has long been put down to the unilateral treaty abuse decree, passed by the Swiss government in 1962.
    December 01 1998
  • Minimum alternative tax applies to all companies
    Indian tax professionals have long debated whether the minimum alternative tax applies to foreign companies doing business in India through permanent establishments.
    December 01 1998
  • Aprile Srl, in liquidation and Amministrazione delle Finanze dello Stato
    Charges having equivalent effect — Recovery of sums paid but not due — Procedural time-limits under national law.
    November 17 1998
  • germanybox-nov98.gif
    Gaining credit in Germany
    Though contrary to European law, foreign shareholders in Germany are prevented from claiming a tax credit available to German nationals. But, as Hans-Jörg Fischer of Clifford Chance, Frankfurt, explains, the courts may well assist foreigners to claim their full entitlement
    November 01 1998
  • US classifies software deals
    After two years of discussion, the IRS has finalized the rules covering the classification of software transactions. Alan Levenson and Alan Shapiro, Deloitte and Touche LLP, San Jose & Washington DC, examine the consequences for software developers around the world
    November 01 1998
  • Shipping to suffer in Norway budget
    The Norwegian government has revealed its proposed budget for 1999. Plans include a one percentage point increase in personal and corporate income tax to 29%.
    November 01 1998
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