Global Tax Advisor Archive 

The following is all archived Global Tax Advisor content

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2010


November 2010

  • IRS Releases Draft Regulations for Reporting Uncertain Tax Positions
  • Hungary Extends Reduced Corporate Tax Rate
  • US Proposes Increased R&D Tax Benefits
  • Tax Court Judges Form New International Association
  • Japan Amends CFC Rules

 

September 2010

  • Canadian Financial Institutions May Get Nasty US Withholding Tax Surprise
  • OECD Releases Model Treaty Updates and Transfer Pricing Guidelines
  • CRA’s 2010 Report Card on Mutual Agreement Program
  • Austria Proposes Interest Deductibility Changes
  • Exida.com – FCA Upholds Non-Resident's Late Filing Penalties

 

    August 2010

    • Lehigh Cement —Taxpayer Wins GAAR Appeal
    • CRA Ruling — Canco Can Re-Deploy Excess Cash Outside Canada
    • Canadian Bank Branch-Managed Loans Excluded for Thin Cap
    • Australia Announces New Resources Tax Regime
    • China Drops Its Gloves in Transfer Pricing Challenges

 

    July 2010

    • Xilinx – US Court Upholds Treatment of Employee Stock Options Under Cost-Sharing Arrangement
    • IRS Unveils Draft Form for Reporting Uncertain Tax Positions
    • OECD Launches Country Review Program on Exchange of Information
    • New US Economic Substance Doctrine Has Teeth
    • Netherlands Studies Tax System Reforms
    • US to Require Extensive New Reporting if Doing Business in US

 

May 2010

  • 2010 UK Budget Receives Royal Assent
  • Tax-Free Sale of a US Holdco’s Target Shares
  • US Steps Up Disclosure Requirements for Foreign Financial Institutions
  • Canada Signs New Treaty Protocol with France
  • UK Residency Ruling Consistent with Administrative Guidelines

 

February 2010

  • U.S. Customs Information Requests — Best Chance to Avoid Penalties?
  • WHT Applies to Non-Cash Remuneration Paid to Non-Resident Employees
  • FMC Technologies — Non-Resident WHT Catch-22 Upheld
  • More CRA Guidance on Canada-U.S. Treaty's Hybrid Entity and LOB Rules
  • IRS To Require Detailed Reporting of Uncertain Tax Positions

 

January 2010

  • RCI Trust — FCA Rules that CRA Not Required to Issue Section 116 Certificate
  • Unpaid Amounts Election to be Filed by Original Debtor and Creditor
  • Pechet — FCA Agrees Interest Owed on Unremitted WHT Despite Nil Tax Liability
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