Leveraging or Capitalizing?
Strategies discusses the main tax implications of leveraging or inserting more capital into Mexican taxpayers and later repatriating the funds.
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M&A in Argentina
Tax related issues are critical when structuring a transaction involving an Argentinean target entity. For example, generally, a foreign entity acquires a target entity directly, rather than through an Argentinean holding company to avoid capital gains tax on the sale of shares.
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Consider Treaties in Analyzing Argentina
Thin-Cap Rules Planners need to consider treaties in determining the role of Argentina thincapitalization rules.
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Brazil’s new Binding Precedent Law
Brazil’s new Binding Precedent Law has helped to settle dozens of substantially similar tax cases, so far all to the benefit of taxpayers.
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Brazil's IOF Tax Rates
New IOF tax rates on certain foreign currency exchange transactions in Brazil.
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Mexican Foreign Trusts
Strategies takes a look at the treatment of foreign trusts under Mexican tax law.
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Maquiladoras
The Mexican Authorities continue to get tough on Mexican taxpayers and now on the maquiladora industry.
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