Deficit commission leaders propose cuts in US federal tax expenditures, spending

Jon Almeras, Deloitte Tax LLP, Washington DC Erskine Bowles and Alan Simpson, the co-chairs of the president’s bipartisan deficit commission, unexpectedly released a draft proposal on November 10 outlining their recommendations for tax reforms – including the elimination of federal tax expenditures – and spending cuts to address the nation’s long-term fiscal problems. The draft [...]

As the sun sets on 2010 – Year end tax changes in the United States

Laura Kelly, McCarter & English LLP, USA Unless Congress acts, many tax cuts and tax rate reductions created by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) and the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) will automatically disappear (“sunset”) after December 31, 2010. Some of the most notable [...]

Singapore: WHT on management and technical assistance fees

Edmund Leow, Jack Wong and Allen Tan Baker & McKenzie.Wong & Leow, Singapore This report will briefly explain and highlight the practical significance of the administrative concession recently announced by the IRAS in respect of withholding tax on management and technical assistance service fees. The administrative concession will be of interest to all multinational companies [...]

China’s new tax platform for Business Restructuring

Yun Wei, Dr Bernd-Uwe Stucken and Matthias Mueller, Salans, Shanghai I. Background on Notice 4 In 2009 SAT set up a framework – through Circular 59 – to tax business restructuring. Circular 59 imposes on a business restructuring either general tax treatment (“General Treatment”) or special tax treatment (“Special Treatment”). Special Treatment allows a party [...]

Dozens of Stakeholders From Around Globe Raise Concerns on FATCA Regime

Dozens of foreign banks, foreign insurance companies, professional associations, and other stakeholders around the world are asking the Internal Revenue Service for exceptions and clarifications to broad new reporting and disclosure agreements under the Foreign Account Tax Compliance Act (FATCA). Stakeholders have requested that IRS trim back the impact of the new law, which requires [...]

India: Foreign share transfers tax proposal

S. S. Palwe and Pritin Kumar Deloitte, Haskins & Sells, Mumbai The Direct Taxes Code Bill, 2010 (DTC), presented to the Indian Lower House of Parliament on August 30, 2010, includes a provision that would bring certain overseas transfers of shares or interests in a foreign company within the Indian tax net. Specifically, tax would [...]

Federal Court of Appeal “gets it right” and overturns Tax Court’s Glaxo ruling

Dale Hill, Jamal Hejazi, Mark Kirkey and Pierre Alary, Gowling Lafleur Henderson LLP, Ottawa This article looks at the recent overturning by the Federal Court of Appeal of one of the most significant transfer pricing decisions in Canada. On July 26, 2010, the Federal Court of Appeal (“FCA”) overturned one of the most significant transfer [...]

Prospective UK-Swiss tax deal: How will this work where the EU Savings Directive has failed?

Judith Harger and Farheen Raza, Dewey & LeBoeuf, London This article looks at the proposed agreement to be entered into by the UK and Swiss tax authorities to expand their co-operation to combat tax evasion by UK individuals. Despite comments by tax authorities in the past that final withholding taxes do not reach the OECD [...]

Legal Professional Privilege in the UK and Prudential: If it ain’t broke, don’t fix it

Sean Jeffrey and Maryanna Sharrock, Stephenson Harwood, London This article looks at the issue of legal professional privilege in the UK as it affects tax lawyers and accountants following the recent decision of the UK Court of Appeal in the Prudential Case. This old saying could summarise the recent decision of the UK Court of [...]

Italy: New transfer pricing documentation requirements

Giuseppe Alessandro Galeano & Francesca Marchiori CBA Studio Legale e Tributario, Milan The authors throw light on the new requirements in transfer pricing documentations introduced recently by the Italian tax authorities. Article 26 of the Law Decree no. 78/2010 has introduced a new subparagraph – number 2-ter – in Article 1 of the Legislative Decree [...]

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