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Results: 1-10 of 281

Australian Federal Budget 2017 - 2018
  • DLA Piper
  • Australia, OECD
  • May 9 2017

The Australian Treasurer has handed down his 2017 budget today. In a change from its more dramatic budgets in recent years, the Australian


New German Fund Taxation Rules
  • K&L Gates
  • Germany
  • August 4 2016

After many years of discussions and various proposals that were later dismissed, the German legislature last month finally passed a law that


Budget 2012: changes to the tax rules for partnerships
  • McMillan LLP
  • Canada
  • April 1 2012

Section 88 of the Income Tax Act (Canada) (the "Tax Act") applies on an acquisition of control of one taxable Canadian corporation (the "Subsidiary") by another taxable Canadian corporation (the "Parent") to permit the Parent to increase (or "bump") the tax cost of certain assets owned by the Subsidiary at the time of the acquisition of control upon a subsequent winding-up of the Subsidiary into, or a vertical amalgamation of the Subsidiary with, the Parent


Nordstrom's preliminary injunction denied - VCI 2 is still on
  • Reed Smith LLP
  • USA
  • October 25 2011

With just one week left before the end of California's second Voluntary Compliance Initiative ("VCI 2"), a trial court considered whether the VCI 2 compliance period should remain open past October 31 pending a decision on whether one of the key provisions of VCI 2 is constitutional


New Jersey’s ability to impose corporate income tax is limited, partner: appellate court renders decision exempting certain limited partners from the corporation business tax
  • Pepper Hamilton LLP
  • USA
  • September 30 2011

The New Jersey Division of Taxation was just dealt a severe judicial setback in its ability to impose tax on passive corporate limited partners whose only connection to the state was an investment in a limited partnership doing business in the state


Outsourcing the Revenue Department’s discretionary authority to make transfer pricing adjustments: arbitrary and capricious
  • Alston & Bird LLP
  • USA
  • August 31 2011

In 2005, a small firm filed a patent application with the United States Patent and Technology Office (USPTO) for a “system and method” to “analyze tax avoidance of a taxpaying entity.”


California Franchise Tax Board releases guidelines for new voluntary disclosure initiative
  • Manatt Phelps & Phillips LLP
  • USA
  • July 12 2011

In March of this year, Governor Brown signed into law Senate Bill 86, which, among other things, authorizes the Franchise Tax Board (“FTB”) to administer a new California voluntary disclosure initiative (the “2011 California Initiative”) for eligible California taxpayers (each, a “Taxpayer”


HMRC: disguised remuneration
  • Hogan Lovells
  • United Kingdom
  • July 4 2011

The Government is bringing in legislation to tackle arrangements aimed at reducing or avoiding tax or National Insurance liabilities when rewarding employees


HMRC publishes FAQs on proposed anti-avoidance provisions targeting employee benefit trusts
  • Dechert LLP
  • United Kingdom
  • March 4 2011

HM Revenue & Customs published draft legislation in December 2010 to tackle perceived tax avoidance arrangements using employee benefit trusts and other vehicles to reward employees whilst seeking to avoid the payment of tax


New anti-avoidance provisions targeting employee benefit trusts
  • Dechert LLP
  • United Kingdom
  • December 13 2010

HM Revenue & Customs published on 9 December draft legislation to tackle perceived tax avoidance "disguised remuneration" arrangements which use employee benefit trusts and other vehicles to reward employees whilst seeking to avoid the payment of income tax and national insurance