Baker & McKenzie: 2012-13 Federal Budget: Spreading the benefits of the boom...but not to foreign investors by Baker & McKenzie Australia on 5/9/2012 The Treasurer has delivered the 2012-13 Budget. As part of a concerted effort to ensure a budget surplus (of $1.5 billion), the promised company tax cuts have been scrapped and the tax burden for foreign investors has been...more
Transfer Pricing — and it’s Impact on M&A Transactions by White & Case LLP on 5/4/2012 Originally published in ACQUISITION INTERNATIONAL 53: SECTOR SPOTLIGHT: Transfer Pricing and it’s Impact on M&A Transactions, April 2012. Mergers and acquisitions raise a whole host of transfer pricing issues from tax...more
You Can’t Spell “Subchapter C” Without E&P: Proposed Treasury Regulations Clarify the Rules Concerning the Allocation of Earnings... by Sutherland Asbill & Brennan LLP on 4/18/2012 On April 13, 2012, Treasury and the Internal Revenue Service (the IRS) issued proposed regulations that aim to clarify the rule of Treas. Reg. § 1.312-11(a), which concerns the allocation of earnings and profits in tax-free...more
Tax Efficient Licensing Solutions through the Netherlands by Cees Frans Greeven on 3/13/2012 License companies are treated favourably in the Netherlands. In fact, it can be argued that the Netherlands is the world’s best jurisdiction to establish license companies. By virtue of the Netherlands’ extensive...more
Morguard Corporation v. The Queen – When will a “break fee” be considered income? by Fraser Milner Casgrain LLP on 3/7/2012 In Morguard Corporation v. The Queen, 2012 TCC 55, Justice Boyle of the Tax Court of Canada considered whether a “break fee” received by a predecessor of the Appellant (for the purposes of this discussion, the “Appellant”) in...more
US Law Firms enter Australia by stephen moss on 3/4/2012 Most law firm Managing Partners would agree that the pace of change in the legal services sector is accelerating. Changes in the past 18 – 24 months have outstripped the two previous decades. I predict that 2012 will...more
What You Need to Get Done Now If You Want to Sell Your Company in 2012 by Mintz Levin - Corporate & Securities on 2/24/2012 One of today’s most discussed political topics is the expected expiration of the Bush tax cuts after December 31, 2012. If Congress doesn’t act, among other things, the individual U.S. federal income tax rate...more
Indian Supreme Court Holds for Vodafone by King & Spalding on 2/20/2012 On January 20, the Indian Supreme Court handed down a major victory for foreign investors in the landmark case of Vodafone International Holdings B.V. The Vodafone case arose from Vodafone’s 2007 acquisition...more
The 2011 Form 990: More than Simple Tinkering at the Margins by McDermott Will & Emery on 2/7/2012 While recent changes to the Form 990 make it more reader friendly, filing organizations must carefully review it for substantive changes to determine the impact on their reporting requirements, particularly tax-exempt...more
Comcast Loses California NBI and Non-Unitary Appeal: SBE Finds Comcast Unitary With QVC and MediaOne Termination Fee Business... by Reed Smith on 2/7/2012 On February 2, the California State Board of Equalization voted 3-2 against Comcast, holding that (1) Comcast was unitary with majority-owned QVC and (2) the fee Comcast received for a failed merger with MediaOne was...more
IRS Joins FCPA Enforcement by Thomas Fox on 1/31/2012 At the recent ACI FCPA Boot camp, held in Houston, there was an interesting new angle presented in the enforcement panel. Clarissa Balmaseda, a special agent in charge of Internal Revenue Service (IRS) criminal investigation,...more
IRS Releases Form of Information Return for Corporate Actions Affecting Stock Tax Basis by Wilson Sonsini Goodrich & Rosati on 1/12/2012 On January 13, 2011, Wilson Sonsini Goodrich & Rosati issued an alert that described certain tax reporting requirements for any domestic or foreign corporation that undertakes an "organizational action," such as a merger,...more
Beware The Intermediary Sale Corporation by Charles (Chuck) Rubin on 1/5/2012 There are acquisition companies out there that promote a benefit to ‘C’ corporation shareholders that are looking to sell their business. If the corporation sells its assets, there will often be substantial corporate gains...more
Global Tax Report - December 2011 by White & Case LLP on 1/2/2012 In This Issue: Czech Republic — Investing in the Czech Republic; France — Inbound Investments Made by Non-Resident Investors; Germany — European Court of Justice: German WHT on Dividends Paid to EU/EEA Minority;...more
M&A Agreements: Opportunities And Perils In Asset Acquisitions by Jackson Walker on 12/28/2011 Table of Contents: I. INTRODUCTION ... 1 II. ALTERNATIVE STRUCTURES FOR TRANSFERS OF BUSINESSES ...... 3 A. Common Threads; Alternatives ... 3 B. Mergers and Consolidations ... 4 C. Purchases of Shares... 5 D....more