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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)
Download PDF of July 2010 Issue of Practical International Tax Strategies
27 Aug 2010
In This Edition
International Tax Planning
U.S.--Tax Legislation Affecting Foreign Transactions Enacted into Law
By Stephen L. Feldman, Joy S. MacIntyre and Remmelt A. Reigersman (Morrison & Foerster LLP) p. 2
U.S.--Foreign Account Tax Compliance: Withholding and Information Reporting Requirements on “Withholdable Payments” to Foreign Entities
By Angelo Ciavarella, Ruth N. Holzman and Jeffrey E. Kaylor (Reed Smith LLP) p. 4
Some Firms OK International Tax Changes for U.S. Tax Credits
Reuters p. 14
Belgium--Belgian Taxation of Non-Resident Investment Companies Contrary to EU Law?
By Patrick Smet and Christopher Thompson (Allen & Overy LLP) p. 9
China--Transfer Pricing and Service Transactions
By Cecilia Lee (PricewaterhouseCoopers, China) p. 3
New Protocol to Barbados-China Double Tax Agreement Enters into Force
By William Zhang, Lawrence Hu and Angel Wang (MWE China Law Offices) and Thomas W. Giegerich, Kumar Paul and John Engel (McDermott Will & Emery LLP) p. 10
Mexico--Mexican and Brazilian Thin Capitalization Rules
By Carlos Montemayor, Adriana Rodriguez, Fernanda Amaral and Cesar Dondiego (PricewaterhouseCoopers Mexico) p. 14
Highlights
New Law Targets Foreign Tax Credits
The Education Jobs and Medicaid Assistance Act includes tax provisions that will limit the use of foreign tax credits by U.S. companies. The law will prevent companies from claiming foreign tax credits before the taxpayer declares the related foreign income. Other provisions will treat Section 304 deemed distributions as dividends subject to withholding tax. Page 2
Chinese Transfer Pricing Enforcement—Strategies for Supporting Service Charges from Overseas Affiliates
China’s several levels of tax authorities are shifting their transfer pricing focus to cross-border intercompany services. Several strategies for developing effective TP methodology and practices are suggested. Page 3
Start Now to Prepare for FATC Changes Due in 2013
The FATC Provisions (Sections 1471 through 1474) will require 30 percent withholding on payments to foreign banks and investment companies. Reporting requirements will be onerous. Although the Provisions won’t go into effect until 2013, companies should prepare now for the changes. Page 4
New Amendments to the Barbados-China Tax Agreement: Harder for Foreign Investors to Qualify
The Double Tax Agreement will still reduce Chinese taxes on dividends and capital gains; but fewer foreign investors will qualify. An examination of the new provisions, and a discussion of ways to meet the conditions. Page 10
Practical US/International Tax Strategies Issue Archives
15 Apr 2008
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