Search results for

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

ICI has taken its case for consortium relief to the European Court of Justice. The Advocate-General’s opinion may not satisfy ICI, but it does imply the liberalization of consortium relief for EU businesses. By Murray Clayson of Freshfields, London

Octav Botner, founder of Nissan UK, has issued a writ against the Inland Revenue for malicious prosecution. The writ also names two former Inland Revenue inspectors; Robert Brown, now with Ernst & Young and John Cawdron, now with Price Waterhouse.

A special report prepared by Michael Knee, Washington and Robert Misey, Nashville Deloitte & Touche LLP

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.

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.

McDermott, Will & Emery recruits en masse

EC Tax Law

For the first time, Deloitte Touche Tohmatsu has released its worldwide tax fee income results.

An international group of investigators is said to be examining the tax affairs of global media group News Corporation. The rumoured investigation is thought to involve senior tax investigators from tax authorities in the UK, US, Australia and Canada. A spokesman for the UK's Inland Revenue would neither confirm nor deny the story, adding that the affairs of individual companies are never discussed. However a prominent international tax lawyer has told International Tax Review that even if there is as yet no investigation, the adverse publicity will probably ensure one.