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By Deborah Bailey, Trevor Gee, Robert Walley
When John Hadley invented the sextant, could he have foreseen the development of the global positioning system?
After years of political deliberation, contentious debate and practical obstacles, the EU Savings Directive (Directive), adopted in 2003, finally takes effect on 1 July 2005. As from that date, the 25 EU Member States, five non-EU countries and 10 dependent and associated territories will apply "equivalent" measures on savings income. Although the legal scope of the Directive does not extend beyond EU borders, its implementation will, in fact, affect those other countries and territories that ha
Contents: Hong Kong - Court Rules on Source of Brokerage Company's Income, India - Tribunal Rules on Taxability of Service Fees under India-U.S. Treaty / AAR Rules on Application of India - U.A.E. Treaty, Japan - 2005 Tax Law Changes Affect Inbound Investment / New Law May Prohibit Japanese Branch Operations of Foreign Companies, Macau - Government Restricts Activities of Offshore Companies, Philippines - Corporate Tax and VAT Changes Enacted, Taiwan - MOF Issues Rulings on Taxation of Forei
This article covers recent tax developments in Canada, Chile, Mexico and The United States.
Israel: Parliament Passes Multi- Year Reform in First Reading / Court Issues Ruling on MAP in Tax Treaties.
The U.S. imposes income tax on the worldwide income of its citizens and green card holders even if they reside overseas. U.S. citizens and certain green card holders residing overseas are also subject to U.S. gift and estate tax on transfers of worldwide assets.
By Ian Carpenter
On 28 April 2005 U.S. and Chinese officials announced that the Port of Shanghai will become the 36th operational Container Security Initiative (CSI) port. Under the CSI, U.S. Customs and Border Protection has entered into bilateral partnerships with foreign customs officials to identify high risk cargo containers and pre-screen them before they are loaded on vessels destined for the U.S.
This article discusses international tax developments and has been prepared by professionals in the member firms of Deloitte Touche Tohmatsu.
Last fall Congress passed the American Jobs Creation Act of 2004 (the Act), which made extensive changes to tax laws governing executive compensation. This third segment of a four-segment series focuses on the changes in basic rules for nonresident aliens, and stock compensation of insiders in inverted corporations.
This article has been prepared by professionals in the member firms of Deloitte Touche Tohmatsu.
A number of controversial issues remain unresolved with respect to the interpretation of the German thin capitalization rules. One issue, in particular, concerns third party debt with shareholder recourse.