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  • 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.
  • 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).
  • A special report prepared by Michael Knee, Washington and Robert Misey, Nashville Deloitte & Touche LLP
  • A special report prepared by Christopher Fitzgibbon of Deloitte & Touche, London
  • 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).
  • 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
  • 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
  • A special report prepared by Jonathan Stuart-Smith and Tomohiko Kaneko of Deloitte Touche Tohmatsu, Tokyo
  • 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
  • US defence contractor Raytheon has completed the acquisition of the Hughes defence electronics business from General Motors. The deal is worth $9.5 billion and makes Raytheon the world's third-largest defence and aerospace group.