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Practical International Tax Strategies
Proven Solutions to Help You Maximize After-Tax Profits for Your International Operations Practical International Tax Strategies tells you in clear business language how your colleagues at leading companies are reducing their tax burden in international transactions. Subscribers participate in a dialogue of leading practitioners who consider the best strategies for coping with important new tax rulings, regulations and court decisions, originating both from the US and international sources. To Subscribe> Scroll down to view current issue and archives. |  |
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Now Available: Global Transfer Pricing Solutions: Fifth Edition Minimize Your Tax Exposure Worldwide 
Add to Cart | Reduce your in-country tax exposure when you build a global business strategy that balances your business goals with sound transfer pricing and tax compliance policies. You'll find insight into the major worldwide transfer pricing regimes with in-depth analysis of proactive transfer pricing management, e-commerce, intellectual property, and much, much more. Learn More Format: One-Volume Report
Price: $385
Pages: 450
ISBN: 978-1-935128-04-5 |
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Current Issue: (for subscribers only)
Practical US/International Tax Strategies Issue Archives
31 Jul 2012
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Download PDF of April 30, 2013 Practical International Tax Strategies
22 May 2013
IN THIS ISSUE
U.S. Court Rulings May Bring Relief for Netting Interest on Overpayments and Underpayments of Tax
Recent judicial decisions may offer a fairer method of offsetting tax underpayments against overpayments of federal tax for overlapping consolidated groups. Taxpayers should examine their IRS account transcripts for overlooked claims before the statute of limitations expires. Page 2
Limited Partnerships are Pass-Though Entities, According to Australian Court
Under a recent Australian Court holding, U.S. investors that invest into Australia through a limited partnership (LP) may be able to claim the benefits of the Australia-U.S. double tax treaty, regardless of the residence of the LP. Page 4
New Tax in India Aimed at Share Buybacks
Multinationals with operations in India have only until May 31 to avoid a new Indian tax on the buyback of Indian shares. The new tax is unlikely to qualify for foreign tax credits in the U.S. Page 8
South Africa Releases Draft Legislation to Reduce Use of Debt Deductions
The draft rules target hybrid debt, transfer pricing, and related party debt, among others. For hybrid debt instruments, the proposals would reclassify debt as equity and reclassify the yield as a dividend. Proposed effective date is January 1. Page 10
TABLE OF CONTENTS
US--Global Netting: Potential Opportunities for Corporate Taxpayers
By James E. Salles, Charles M. Ruchelman and Michael Lloyd (Caplin & Drysdale, Chartered), p. 2
Integrating Foreign Currency Hedges with Respect to Stock Purchase and Sale Agreements
By Steven D. Bortnick (Pepper Hamilton LLP), p. 3
Australia--Court Rules that Limited Partners are the Relevant Taxpayers for Gains Realized by a Limited Partnership
By Nick Malley and Wendy Hartanti (PricewaterhouseCoopers), p. 4
Cyprus--The Cypriot Crisis: What Does It Mean for Cypriot Corporate Structures?
By Alexander Anichkin, Timur Aitkulov, Vladimir Barbolin, Nicholas Rees, Evgeny Soloviev, Julian Traill and Logan Wright (Clifford Chance), p. 5
India--May 31 Deadline for Tax Opportunity Affecting Multinationals with India Operations
By Dharmesh Pandya (DLA Piper), Akil Hirani and Ravishankar Raghavan (Majmudar & Partners), p. 8
South Africa--Revenue Service Continues Increased Scrutiny of Permanent Establishment Exposure Risk
By Jacqui Peart (Ernst & Young, Johannesburg), p. 9
South Africa Issues Draft Rules on Excessive Debt; Comments Requested by May 24, 2013
By Justin Liebenberg and Ide Louw (Ernst & Young, South Africa), p. 10
UK--The UK Patent Box—Tax Benefits for Both UK and Non-UK Companies
By David Wraige and Anne Campbell (Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.), p. 11
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