France: Supreme Court issues formal advice on investment funds
May 31, 2011 in European Tax Service
Virginie Louvel, FS Tax Partner, Avocat, PWC Tax and Legal Services, Landwell & Associés, Neuilly s/ Seine The European Commission last week decided to refer France to the European Court of Justice for its discriminatory taxation of dividends paid to foreign pension and investment funds. Meanwhile, the same issue is working its way through the French [...]
Australia: Minerals Resource Rent Tax – Government accepts recommendations
May 26, 2011 in Asia-Pacific Focus
Craig Bowie, Minter Ellison, Brisbane The Australian Federal Government announced on March 24, 2011 that it would accept all 98 recommendations made by the Policy Transition Group (PTG) which it set up to advise it in relation to the structure of the proposed Minerals Rent Resource Tax (MRRT) and expanded Petroleum Rent Resource Tax ( [...]
Subpart F: Here to Stay?
May 24, 2011 in International Tax Monitor
Heather Hudak Heather Hudak is a partner in International Tax Services at Ernst & Young LLP in Pittsburgh. Everybody is talking about U.S. tax reform, but opinions differ on when it will occur, and how drastic any reform will be; however, it appears likely that whatever model the U.S. tax system takes in the future, [...]
Proposed changes to Dutch tax law: the Tax Agenda
May 23, 2011 in Tax Planning International Review and Forum
Susan Groot Koerkamp and Martine Moor, KPMG Meijburg & Co, The Netherlands I. Introduction On April 14, 2011, the Dutch Deputy Minister of Finance presented the Tax Agenda, which outlines the Dutch Cabinet’s long-term policy position on changes to the current Dutch tax system. The Tax Agenda forms the starting point for a series of [...]
India: Mark-to-Market
May 19, 2011 in Asia-Pacific Focus
Shailendra S Sharma, Singapore l. Understanding the concept of Mark-to-Market Despite stringent regulations, the unprecedented global economic disorder of 2008-2009 had an adverse impact on Indian business. In 2011, following economic resurgence, India has Rupee appreciation of around eight percent against the US$ over the last year, resulting in several companies with foreign currency loans [...]
USA: Witnesses to State Sharp Views on Rules For Reporting Nonresident Alien Interest
May 17, 2011 in International Tax Monitor
Nearly a dozen witnesses are expected to express sharp views to the Internal Revenue Service at a May 18 hearing about proposed regulations (REG-146097-09) that would require U.S. banks to report deposit interest paid to nonresident aliens. While most — including several banking associations — are expected to argue that the regulations are harmful to [...]
Switzerland: Panel Approves Revised Tax Treaties, Clears Way for Parliamentary Approval
May 16, 2011 in International Tax Monitor
GENEVA — A Swiss parliamentary committee May 13 gave its approval to 12 revised double taxation treaties, clearing the way for the full parliament’s approval in June. The Foreign Affairs Committee of the Council of States approved the treaties signed by the Swiss government with the Netherlands, Turkey, Tajikistan, Japan, Georgia, Poland, India, Germany, Kazakhstan, [...]
Transfer Pricing Rules and Practice in the People’s Republic of China
May 12, 2011 in Tax Management International Journal
Luis Coronado, Patrick Cheung, Jessica Tien, and Joanne Su* Ernst & Young, People’s Republic of China * This article is based on a forthcoming chapter in BNA Tax Management’s Transfer Pricing Series. The authors gratefully acknowledge the aid of several of their colleagues, in particular Ali Tse, David Dorson, Magi Zhang, and Bessie Choi from [...]
USA – The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around?
May 11, 2011 in Tax Management International Journal
Michael J. Miller, Esq.,and Ellen S. Brody, Esq. Roberts & Holland LLP, New York, New York* On February 8, 2011, the Internal Revenue Service announced 1 an offshore voluntary disclosure initiative (“2011 OVDI”) for taxpayers with undisclosed foreign income. The 2011 OVDI is similar to the offshore voluntary disclosure program that was in effect from [...]
Japan: 2011 tax reform proposals and disaster-related relief
May 10, 2011 in Asia-Pacific Focus
Nicholas Walters, Deloitte Japan Japan’s 2011 tax reform proposals were announced December 16, 2010 and included a five percent reduction in the effective rate of corporate income tax. These reforms were due to generally take effect from April 1, 2011, the start of the new financial year. However, due to opposition in the Diet, it [...]
