The Netherlands and China signed a new Tax Treaty for the Avoidance of Double Taxation and Prevention of Fiscal Evasion on 31 May. Once in effect (no earlier than 1 January 2014), it will replace the current tax treaty, which...more
On May 17, 2013, the United States Court of Appeals for the Third Circuit issued its opinion in the case of Cooper v. Comm’r of Internal Revenue, ___ F.3d ____, 2013-1 U.S. Tax Cas. (CCH) P50,331. The opinion is a...more
Introduction - Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more
In this issue: - Delivered by Independent Contractors, Undelivered by P.L. 86-272: Order Fulfillment Activities Subject Out-of-State Seller to New York Corporation Franchise Tax - Everything’s Bigger in Texas,...more
India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more
On March 5, Georgia enacted HB 266, which, among other things, eliminates a monthly sales tax on auto leases. The bill responds to a 2012 overhaul of the state’s tax code that mistakenly created a double tax on car leases,...more
The Pennsylvania Supreme Court has held that a taxpayer’s gain from the sale of timberland was apportionable business income using the “functional test” of Pennsylvania’s amended definition of “business income.” Glatfelter...more
In This Article: Federal Government; Alberta; British Columbia; Manitoba; New Brunswick; Newfoundland; Northwest Territories; Nova Scotia; Nunavut; Ontario; Prince Edward Island; Québec/Quebec; Saskatchewan; and Yukon....more
Code Section 2519 is a notoriously difficult section to apply. In 2009, I wrote on article on it for Estate Planning, and ever since I’ve been providing a lot of assistance to others on its operation. So I am always...more
UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more
PPL, an American energy company, bought one of many state-owned British utilities privatized in the 1980s. In 1997, PPL became subject to the U.K.’s new “windfall tax,” which was based in part on “profit-making value”— the...more
The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc.,1 (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation...more
Okay, let’s admit it—plenty of us had absolutely no interest whatsoever in becoming tax specialists when we started law school. And so here we are, all these years later, serving as employment counsel to our corporate...more
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