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  • 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
  • Hybrid branches face stern test
    The US Internal Revenue Service has signalled its intention to limit the tax advantages available to some hybrid branches. Joseph DeCarlo of Price Waterhouse LLP, and Alan Granwell and Dirk Suringa of Ivins, Phillips & Barker, Washington DC report
    March 01 1998
  • Germany: reform by example
    Hans-Peter Niedrig and Axel Schiller of KPMG Düsseldorf use practical examples to illustrate the real affects of changes to German tax law, including the taxation of reorganization profits, accruals for anticipated losses, and loss deductions for shell purchases
    March 01 1998
  • China: layered incentives draw investors
    China offers foreign investors a host of tax incentives, many of which can run simultaneously. Kenneth Leung of Clifford Chance, Hong Kong looks at the opportunities, the criteria for qualification and the interaction of the available incentives
    March 01 1998
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