Date |
Title |
|
7 March 2012
|
Newsletter
This issue features a topic of regional significance:
- structuring investment in China with the points of view of major jurisdictions: France, Luxembourg, the Netherlands, Switzerland and the UK
- provides developments on corporate tax in various European jurisdictions: France, Germany, the Netherlands, Spain and the UnitedKingdom
|
|
March 2012
|
Client/Legal Alert
UK government clamps down on enveloping of high-value residential property in corporate structures. Stamp duty land tax and capital gains tax charges likely to discourage use of such structures for residential investment in the future.
|
|
March 2012
|
Newsletter
This is the March 2012 edition of China Tax Monthly.
|
|
29 February 2012
|
Newsletter
This is the February 2012 edition of China Tax Monthly.
|
|
27 February 2012
|
Client/Legal Alert
On the 24th of February, the Dutch Supreme Court ruled that FOREX gains on so-called "tainted group debts" are exempt from Dutch corporate income tax.
|
|
27 February 2012
|
Book
Baker & McKenzie's inaugural Insights report, an in-depth look at some of the key trends and developments in the global private equity industry.
|
|
23 February 2012
|
Client/Legal Alert
On 14 February 2012, the Internal Revenue Service published in the Federal Register several sets of regulations addressing the "splitting" of foreign taxes from the income on which they are imposed for purposes of the foreign tax credit allowed by the Internal Revenue Code. The guidance represents a major effort by the Service to curtail "cross-crediting" of foreign taxes, that is, a US taxpayer's ability to offset foreign tax on an item of income against US tax on another item of foreign income.
|
|
22 February 2012
|
Newsletter
The February issue of Tax News and Developments discusses several recent IRS guidance updates, including Tangible Property Costs, Foreign Tax Credit Splitters, the OVDI 2011+ Program, Foreign Base Company Sales Income, FATCA, Taxpayer's Rescission of Corporate Reorganization, the COI pond and Conduit Financing Regulations.
|
|
14 February 2012
|
Client/Legal Alert
On 8 February 2012 the IRS issued proposed regulations governing the phased implementation of the Foreign Account Tax Compliance Act. These provisions include a new and additional withholding tax compliance regime, effective in 2013. This client alert will address the changes and modifications of prior guidance as well as other key features of the proposed regulations.
|
|
3 February 2012
|
Client/Legal Alert
France has formally asked Luxembourg to renegotiate the current tax treaty concluded with France so that the capital gain realised upon the sale by a Luxembourg company of shares in a French real estate oriented company would become taxable in France.
|
|
February 2012
|
Client/Legal Alert
The SPF regime was introduced by the Law of 11 May 2007 (SPF Law) in order to create a specific legal framework for individuals managing their private wealth. The Law of 18 February 2012 (SPF Amended Law) amending the SPF regime will increase the interest of this secured and tax efficient investment vehicle.
|
|
February 2012
|
Client/Legal Alert
AVD v. Comptroller of Income Tax [2011] SGITBR 3, Income Tax Board of Review, 13 October 2011
The decision of the Income Tax Board of Review (the Board) in the abovementioned case shows that it is possible to successfully challenge the Comptroller of Income Tax (the Comptroller) in the exercise of his discretion if the Comptroller did not fairly consider the taxpayer's application. |
|
February 2012
|
Client/Legal Alert
The 2012 Budget was delivered by the Minister for Finance on 17 February 2012. In line with forecasts, the economy grew 4.9 percent in 2011 and Singapore ended the financial year in a strong surplus position. Notwithstanding the uncertain economic outlook in the US and Europe, prospects continue to remain bright in Asia. Therefore, this year's Budget focuses on strengthening Singapore's fundamental competencies to leverage on Asian growth.
|
|
February 2012
|
Client/Legal Alert
Last week, the Financial Action Task Force (FATF) released its revised recommendations on anti-money laundering (AML) standards. The FATF is the international body that develops global standards on measures to combat money laundering and terrorist financing.
|
|
February 2012
|
Client/Legal Alert
The UK tax authorities (HMRC) have recently issued a new Statement of Practice relating to Advance Thin Capitalisation Agreements (ATCAs). This new guidance provides increased opportunities for taxpayers to obtain certainty on a unilateral basis around the application of the UK transfer pricing rules to a wider range of debt financing arrangements.
|
| |