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  • Germany
    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
  • France
    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
  • Canada
    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
  • 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
  • Skadden, Arps helps Compaq in bid for Digital Equipment
    Compaq Computers is to merge with Digital Equipment Corporation. The deal, valued at approximately $9.6 billion, is the largest in the history of the computer industry and will create the world's second-largest computer company after International Business Machines (IBM).
    March 01 1998
  • PROPOSED MORATORIUM ON STATE TAXATION OF INTERNET COMMERCE
    The Internet Tax Freedom Act – legislation seeking to impose a national moratorium on US state and local taxation of the Internet and electronic commerce conducted over the Internet – was introduced in March 1997 in the US Congress by representative Christopher Cox, a Republican member of the House from California, and senator Ron Wyden, a Democratic senator from Oregon.
    March 01 1998
  • Russia
    Russia's tax treaty programme continues to evolve rapidly. Russian treaty negotiators have been extremely successful in modernizing Russia's treaties, and as a result 17 new double taxation conventions came into force during 1997.
    March 01 1998
  • Illustration
    The Taxation of Intangibles (Special supplement): United Kingdom
    A special report prepared by Christopher Fitzgibbon of Deloitte & Touche, London
    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
  • Chadbourne & Parke works with Tommy Hilfiger
    US-based fashion design house Tommy Hilfiger has announced that it will buy Pepe Jeans USA and Tommy Hilfiger Canada for $1.15 billion.
    March 01 1998
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