Search results for

The finance ministers of the world's biggest economies will impose sanctions against tax havens that have failed to increase tax transparency, five months after vowing to name and shame uncooperative jurisdictions.

Singapore and Australia have signed an amended tax treaty enabling more exchange of information on potential tax abuse.

Two jurisdictions have moved onto the OECD's white list of compliant jurisdictions, after signing a slew of information exchange agreements.

France will introduce a tax on carbon emissions on January 1 2010, seven months earlier than predicted.

David Cuellar Adriana Rodriguez Karina Perez Three advisers became partners of PricewaterhouseCoopers's tax practice in Mexico on July 1. David Cuellar and Adriana Rodriguez practise in the international tax services (consulting and structuring) team and Karina Perez is a dispute resolution specialist.

Frank Ng Frank Ng, the former commissioner of the Large and Mid-Size Business (LMSB) division of the Internal Revenue Service in the US, has joined Ernst & Young. He will be a member of the tax controversy and risk management services practice.

By Ralph Cunningham

Sean Foley Landon McGrew The US Court of Appeals for the Ninth Circuit recently issued an opinion, in Xilinx, Inc v CIR, No. 06-74246 (9th Circuit May 27 2009), holding that the arm's length standard described in the section 482 regulations does not apply to certain costs incurred in connection with cost sharing arrangements. Rather, the court held that the section 482 regulations in effect at the time the taxpayer's tax returns were filed required the sharing of all costs incurred in connection with cost sharing arrangements, even if such costs would not have been shared by unrelated parties acting at arm's length. The Xilinx decision reverses an earlier Tax Court case (Xilinx, Inc v CIR, 125 T.C. 37 (2005)) that held that such costs were not required to be shared under section 482. On August 12 2009, Xilinx filed a petition for rehearing to the ninth circuit, arguing that the court had improperly abandoned the arm's length standard.

Umurcan Gago Baris Yalçin Corporate treasurers in Turkey have recently become more inclined to use modern corporate treasury techniques, many of which may be regarded as plain vanilla transactions in developed markets but are perceived as rocket science in Turkey.

Hatasakdi Na Pombejra Thailand has tax incentives on debt restructuring for a transaction done before December 31 2009. There is an issue with what type of debt restructuring qualifies for the tax incentives. The Revenue Department by its notification of May 29 2009 seems to nail down the non-performing loan (NPL) issue only, for example default from three months onwards. Financial institutions would normally want to do the debt restructuring before the NPL to make its financial status better. Taking into account the requirement of the Revenue Department, any debt restructuring before NPL will not be entitled to the tax incentive.