ITR Search | International Tax Review

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

United States

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

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

EU steers UK group relief rules

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

March 01 1998

Slaughter & May helps dispose of Spillers

Switzerland's consumer products group Nestlé is to purchase the Spillers pet food business from UK food group Dalgety. The deal is worth £715 million ($1.2 billion) and is still subject to regulatory clearance. The acquisition will give Nestlé 20% of Europe's branded pet food market.

March 01 1998

FOREIGN DIVIDEND TAX CREDIT REGULATIONS

In the May 1997 edition of International Tax Review we briefly commented on proposed changes to regulations regarding a Norwegian parent company's right to credit for underlying foreign corporate taxes relating to dividends received from foreign subsidiaries. The bill passed parliament and is effective for dividends received from the fiscal year 1997.

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

Expatriate taxation in Europe Survey Part three: The discreet charms of expat tax

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

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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