| 8/24/2010 |
President Signs H.R. 1586 Containing International Tax Provisions
121 KB PDF File |
| 6/8/2010 |
Financial Bank Account Reporting Guidance Revised; Limited Relief Extended
563 KB PDF File |
| 5/13/2010 |
New Law Expands Limitations Period With Respect to the Failure to Report Certain Foreign Activities
101 KB PDF File |
| 4/19/2010 |
French Supreme Court Issues Ruling on Commissionaire Structures and the Creation of French Permanent Establishments
1361 KB PDF File |
| 4/8/2010 |
Chinese Tax Authority Targets Foreign Businesses in China
108 KB PDF File |
| 4/8/2010 |
Chinese Tax Authorities Now Require Transfer Pricing Documentation
103 KB PDF File |
| 4/8/2010 |
U.S. Tax Court Decision on Xilinx
104 KB PDF File |
| 3/1/2010 |
United States and Chile Sign a New Income Tax Treaty
106 KB PDF File |
| 3/1/2010 |
United States and Hungary Sign a New Income Tax Treaty
108 KB PDF File |
| 2/19/2010 |
Obama Administration Outlines New Proposals to Reform
113 KB PDF File |
| 2/10/2010 |
New Protocol to United States – France Income Tax Treaty Enters into Force Creating Possible Refund Opportunity for Certain Dividend and Royalty Payments
103 KB PDF File |
| 2/10/2010 |
United States-Italy Income Tax Treaty Enters into Force
108 KB PDF File |
| 1/14/2010 |
Tax Court Rules Against IRS in VERITAS Software Corp. Cost-Sharing Trial
104 KB PDF File |
| 1/14/2010 |
Tax Court of Canada Rules in Favor of GE Capital Canada in Guarantee Fee Trial
98 KB PDF File |
| 12/16/2009 |
Mexican Tax Reform of 2010
162 KB PDF File |
| 11/3/2009 |
New Protocol Amending United States - Switzerland Income Tax Treaty Signed on September 23, 2009
155 KB File |
| 9/23/2009 |
IRS Extends Deadline for Foreign Bank Account Reporting Under Voluntary Disclosure Program
150 KB PDF File |
| 8/19/2009 |
Internal Revenue Service Issues Additional Guidance on Foreign Bank and Financial Accounts
157 KB PDF File |
| 7/14/2009 |
Temporary Relaxation of German NOL Limitation and Interest Barrier Rules
185 KB PDF File |
| 6/18/2009 |
United States and Hungary Agree on New Income Tax Treaty
174 KB PDF File |
| 6/4/2009 |
Internal Revenue Service Expands Obligation to Report Foreign Bank and Financial Accounts; Issues Guidance on Voluntary Disclosure
161 KB PDF File |
| 5/13/2009 |
Obama Administration Outlines Proposals to Reform International Tax Provisions and to Strengthen Enforcement of Offshore Tax Disclosures
179 KB PDF File |
| 4/9/2009 |
Stricter Reporting Requirements for U.S. Transferors of Property to Foreign Corporations
179 KB PDF File |
| 4/9/2009 |
New Filing Requirements for Computing Disqualified Interest Expense Under Section 163(j)
155 KB PDF File |
| 4/6/2009 |
Transfer Pricing News - April 2009
357 KB PDF File |
| 2/11/2009 |
Significant Changes to United States – France Income Tax Treaty under New Protocol
163 KB PDF File |
| 2/11/2009 |
Relaxation of Rules Relating to Certain Loans from Controlled Foreign Corporations to United States Taxpayers
149 KB PDF File |
| 2/5/2009 |
The Temporary Cost-Sharing Regulations
217 KB PDF File |
| 1/19/2009 |
Conduit Financing Proposed Regulations Affect Certain Disregarded Entities
28 KB PDF |
| 1/19/2009 |
Vodafone Case: Holding Companies with Investments in India Affected
28 KB PDF |
| 1/19/2009 |
Final Regulations on the Application of Subpart F to Certain Contract Manufacturing Arrangements
28 KB PDF |
| 1/8/2009 |
IRS Issues Final and Temporary Cost-Sharing Regulations
25 KB |
| 12/18/2008 |
Fifth Protocol Amending the United States-Canada Income Tax Treaty is in Effect
29 KB PDF File |
| 12/11/2008 |
United Kingdom (“UK”) Taxation of European Union (“EU”) Sourced Dividends Ruled Unlawful by High Court in London
30KB PDF File |
| 12/3/2008 |
The United Kingdom Pre-Budget Report (the “Report”) Announces an Exemption Regime for the Taxation of Foreign Profits to be Introduced in the 2009 Finance Act
49KB PDF File |
| 11/21/2008 |
United States Tax Authorities Consider Changes to USRPI Determination
34KB PDF File |
| 11/18/2008 |
Internal Revenue Service Announces Automatic Penalty Assessment for Late Filing of Form 5471
33KB PDF File |
| 11/18/2008 |
Brazil Exempts Foreign Fixed Income Investments and Loans from IOF Tax
30KB PDF File |
| 10/8/2008 |
Ratified U.S.-Canada Protocol Provides for Refund Opportunity on Interest Withholding Tax
38KB PDF File |
| 10/8/2008 |
IRS Allows Certain Loans from CFC’s Without Deemed Income Inclusions
32KB PDF File |
| 8/25/2008 |
New Internal Revenue Manual provision mandates stricter scrutiny and regulation of payments to foreign persons
40KB PDF File |
| 8/7/2008 |
Mexican Authorities Repeal Recent Administrative Rule Including Transfers and Transactions from Foreign Banks Under the Cash Deposits Tax
30KB PDF File |
| 8/7/2008 |
New German Change-in-Ownership Rules Severely Restrict NOL Carryovers
32KB PDF File |
| 8/6/2008 |
UK Company’s Interest Owed to Foreign Parent: Deduction Based on Accrual Method
40KB PDF File |
| 8/1/2008 |
Delay in Application of Worldwide Allocation of Interest
28KB PDF File |
| 7/16/2008 |
Technical Explanation of the Fifth Protocol to US-Canada Income Tax Treaty Released July 10, 2008
36KB PDF File |
| 7/8/2008 |
New Tax on Cash Bank Deposits Effective in Mexico
25KB PDF File |
| 7/8/2008 |
Delaware Included as Tax Haven under New Brazilian Tax Law
25KB PDF File |
| 7/7/2008 |
IRS Rules that Partners, not the Partnership, Must File Form 926 for Transfers of Property to a Foreign Corporation
30KB PDF File |
| 7/2/2008 |
International Tax Alert - Italian Government Decree Would Eliminate Favorable Rules on the Taxation of Stock Options
37KB PDF File |
| 6/30/2008 |
IRS Substantially Expands Jurisdiction of the APA Program
26KB PDF File |
| 6/13/2008 |
Brazil Supreme Court Maintains Limited Judicial Exemptions on Social Contributions Tax
26KB PDF File |
| 5/22/2008 |
IRS Simplifies Late Filing Relief Procedures for Certain FIRPTA Transactions
36KB PDF File |
| 5/13/2008 |
Foreign Bank and Financial Account Filing Requirements
74KB PDF file |
| 4/14/2008 |
Ireland Changes in Taxation of Foreign Dividends
27KB PDF file |
| 4/9/2008 |
U.S. Tax Filings for Foreign Companies
39KB PDF file |
| 4/2/2008 |
U.S. Alert: Interest Paid by a German Partnership to a U.S. Partner is Exempt from German Tax under the U.S.-German Treaty
29KB PDF File |
| 3/17/2008 |
UK Disregard Regulations: New Election, if Required, Should be Made by March 31, 2008
25KB PDF file |
| 3/6/2008 |
New Switzerland Witholding Tax Rules Relating to Repatriation and Reorganizations
29KB PDF file |
| 3/6/2008 |
New Proposed Regulations on Contract Manufacturing
39KB PDF File |
| 3/5/2008 |
India Union Budget 2008
686KB PDF File |
| 2/25/2008 |
Third Circuit Court of Appeals Decision Upholds Regulation That May Deny Deductions on Late Filed Returns of Foreign Corporations Conducting Business in the U.S.
29KB PDF File
|
| 2/12/2008 |
Refund Opportunity Under New U.S.-German Protocol
36KB PDF File |
| 2/6/2008 |
Irish Government Publishes Several Changes in Finance Bill for 2008
26KB PDF File |
| 1/16/2008 |
IRS Issues Regulations on Overall Domestic and Foreign Losses
28KB PDF file |
| 1/16/2008 |
Impact of New Treaty Protocol (Fifth Protocol) with Canada on Non-deductible Payments
29KB PDF file |
| 12/19/2007 |
Mexican Single Rate Business Tax (IETU) and U.S. Foreign Tax Credit
24KB PDF File |
| 11/26/2007 |
IRS Directive Makes Audits of IRC §965 Repatriation Mandatory
38KB PDF File |
| 11/20/2007 |
Canadian Withholding on Arm’s Length Interest
26KB PDF File |
| 10/2/2007 |
United States and Canada Sign Fifth Protocol to U.S.-Canada Income Tax Convention
39KB PDF File |
| 9/5/2007 |
2008 German Tax Reforms: Loss Carry-forward Limitation Rules
30KB PDF File |
| 8/22/2007 |
Draft Form 1118 Issued by Internal Revenue Service
30KB PDF File |
| 8/7/2007 |
Tax Rate Changes in the UK, Germany and China
29KB PDF File |
| 7/30/2007 |
UK Issues Management Expenses Anti-Avoidance Guidance
27KB PDF File |
| 7/27/2007 |
German Government Proposes Significant Expansion of Anti-Abuse Rules
27KB PDF File |
| 7/26/2007 |
French Tax Authorities Issue Guidelines Regarding Rules for Group Tax Regime
27KB PDF File |
| 7/26/2007 |
Finalization of Temporary Regulations Clarifying Information Reporting by Foreign and Foreign-owned Domestic Corporations
28KB PDF File |
| 4/24/2007 |
UK Taxation of Foreign Profits
60KB PDF File |
| 4/24/2007 |
British Columbia ULC
27KB PDF File |
| 4/16/2007 |
German Government Approves Draft Tax Reform 2008
39KB PDF File |
| 4/3/2007 |
Proposed FTC Regulations
33KB PDF File |
| 3/26/2007 |
Canada Proposes Major Changes to International Tax Rules
43 KB PDF File |
| 3/22/2007 |
Final Regulations Issued Under Dual Consolidated Loss Provisions
39 KB PDF File |
| 2/26/2007 |
Form 1042 Update
37 KB PDF File |
| 2/23/2007 |
Qualified Patent Cross Licensing Arrangements
30 KB PDF File |
| 2/15/2007 |
IRS Comments on its Developing Position on Requesting Taxpayer FIN 48 Workpapers
30 KB PDF File |
| 2/13/2007 |
Gain Recognition Agreements
30 KB PDF File |
| 2/12/2007 |
Manufacturing Exception to Subpart F Income
31 KB PDF File |
| 2/5/2007 |
Notice 2007-13
30 KB PDF File |
| 1/23/2007 |
IRS Notice 2007-9
29 KB PDF File |
| 12/14/2006 |
Germany: 2007 Annual Tax Bill Tightens Treaty Shopping Rules
25 KB PDF File |
| 12/14/2006 |
German Tax Reform Proposal to Reduce Corporate Tax Rates
26 KB PDF File |
| 11/3/2006 |
Imperial Oil Case Ruling Regarding Canadian Foreign Exchange Losses
30 KB PDF File |
| 11/3/2006 |
US, UK Enter Competent Authority Agreement to Prevent Double Taxation
25.5 KB PDF File |
| 10/23/2006 |
Proposed Dutch Corporate and Individual Tax Cuts
27KB PDF File |
| 9/21/2006 |
Sales and Use Tax in Puerto Rico
27KB PDF File |
| 9/20/2006 |
UK CFC Rules – ECJ Decision in the Cadbury Schweppes Case
32KB PDF File |
| 8/29/2006 |
New Temporary U.S. Transfer Pricing Services and Intangibles Regulations
57KB PDF File |
| 8/11/2006 |
"Technical Taxpayer Rule" for Foreign Tax Credits
34KB PDF File |
| 7/10/2006 |
Private Equity Funds-Tax Efficiencies
34KB PDF File |
| 7/5/2006 |
IRS Issues Additional Guidance on Section 7874 ("Inversions")
44KB PDF File |
| 6/27/2006 |
Treasury Issues Regulations Addressing Related Party Reporting Requirements for Foreign Subsidiaries and Foreign Owned U.S. Corporations
29KB PDF File |
| 6/14/2006 |
Deadline for Filing Form TDF 90-22.1: Report of Foreign Bank and Financial Accounts
29KB PDF File |
| 6/6/2006 |
New Protocol to US-German Income Tax Treaty
25KB PDF File |
| 5/19/2006 |
Temporary Exception from Subpart F for Certain Dividends, Interest, Rents and Royalties
25KB PDF File |
| 5/19/2006 |
Earnings Stripping Regime Adopts Look-Through Rule for Partnership Items
25KB PDF File |
| 5/19/2006 |
Two-Year Extension of Active Financing Exception to Subpart F
25KB PDF File |
| 4/27/2006 |
Lower corporate tax and withholding tax rates proposed in the Netherlands
30KB PDF File |
| 3/23/2006 |
Voluntary Compliance Program for Payments to Foreign Persons Set to Expire March 31
31KB PDF File |
| 3/20/2006 |
International R&D Credits and Incentives Update
29KB PDF File |
| 3/17/2006 |
IRS Relaxes Treaty-Based Return Disclosure Requirements
39KB PDF File |
| 3/14/2006 |
India Union Budget 2006
370KB PDF File |
| 3/13/2006 |
Recent Spain-U.S. Competent Authority Agreement May Present a Refund Opportunity
31KB PDF File |
| 2/21/2006 |
Recent Changes in Italy’s Tax Laws Allow for Step Up in Basis for Certain Assets and a Limited Capital Gains Exemption
31KB PDF File |
| 2/14/2006 |
Possible Refund of Dividend Withholding Tax in Norway
75KB PDF File |
| 2/9/2006 |
Notice 2006-16
127KB PDF File |
| 1/31/2006 |
French Finance Bills
98KB PDF File |
| 11/18/2005 |
UK VAT Refund Opportunity
99KB PDF File |
| 10/14/2005 |
German Federal Tax Court Expands Availability of Treaty Benefits
120KB PDF File |
| 10/10/2005 |
IRS Provides Guidance on Retroactive Section 367(a) Gain Recognition Agreement
36KB PDF File |
| 10/3/2005 |
Canada Withdraws Corporate Tax Reduction
93KB PDF File |
| 8/30/2005 |
Section 965 Guidance
49KB PDF File |
| 6/1/2005 |
Tax Arbitrage: Hybrid Entities
110KB PDF File |
| 5/19/2005 |
Notice 2005-38: New Guidance on Repatriation
120KB PDF File |
| 5/12/2005 |
Deadline for Filing Form TDF 90-22.1: Report of Foreign Bank and Financial Accounts
39KB PDF File |
| 5/12/2005 |
E.U. Customs Duty Refund Opportunity
38KB PDF File |
| 4/11/2005 |
An Overview of Transfer Pricing in Latin America
87KB PDF File |
| 3/23/2005 |
Proposed UK Anti-Avoidance Legislation Poses Major Challenge to U.S. International Tax Planners
52KB PDF File |
| 2/22/2005 |
Tax Saving Alternative for U.S. Exporters
52KB PDF File |
| 1/12/2005 |
Switzerland Reduces Withholding Tax
33KB PDF File |
| 12/1/2004 |
New Filing Requirement for Foreign Disregarded Entities
128KB PDF File |
| 11/1/2004 |
Repatriation
152KB PDF File |
| 10/19/2004 |
Production Activities Deduction Replaces Extraterritorial Income Exclusion
146KB PDF File |
| 10/18/2004 |
European Limited Liability Company Regulations - "Societas Europaea" (SE)
161KB PDF File |
| 10/18/2004 |
Mexico: Proposed Tax Bill For 2005
158KB PDF File |
| 7/14/2004 |
U.S. & Mexico Sign Social Security Agreement
33KB PDF File |
| 6/21/2004 |
Deadline for Filing Form TDF 90-22.1; Report of Foreign Bank and Financial Accounts
36KB PDF File |
| 6/10/2004 |
Form 8802 U.S. Residency Certification Update
33KB PDF File |
| 6/4/2004 |
Brazilian Tax Savings Opportunity - New COFINS & PIS Taxes
42KB PDF File |
| 3/31/2004 |
New U.S.-Japan Income Tax Treaty
51KB PDF File |
| 3/4/2004 |
New Opportunity Created By German Thin Capitalization Rules
42KB PDF File |
| 3/3/2004 |
Insolvent CFC's Can Trigger Ordinary Worthless Stock Deduction
35KB PDF File |
| 1/28/2004 |
New Procedures for IRS Certification of United States Residency
34KB PDF File |
| 1/14/2004 |
New Form 8858 Required for U.S. Taxpayers Owning Foreign Disregarded Entities
34KB PDF File |
| 1/14/2004 |
New German Tax Law Changes To Severely Impact Businesses
909KB PDF File |
| 12/16/2003 |
Changes in the Federal and State Estate, Gift and Generation-Skipping Transfer Tax Laws
35KB PDF File |
| 11/12/2003 |
Proposed Thin Cap Rules for Dutch Companies
43KB PDF File |
| 11/12/2003 |
Split Dollar Life Insurance Policies
35KB PDF File |
| 11/12/2003 |
German Transfer Pricing
41KB PDF File |
| 11/7/2003 |
2004 Retirement Plan Cost of Living Adjustments
545KB PDF File |
| 11/7/2003 |
U.S.-U.K. Double Taxation Agreement & Expatriate Participation in a Foreign Plan
535KB PDF File |
| 10/21/2003 |
New York State Anti-PIC Legislation
1MB PDF File |
| 10/3/2003 |
Transfer Pricing
939KB PDF File |