Tax Management International Forum

What it is

Highly valued by tax professional for providing detailed, country by country approaches to solving specific tax planning questions. Each issue of the quarterly Forum focuses on a single tax issue in the form of a case study. Leading tax experts from 15 counties then illustrate how their tax regimes would deal with this question. The countries included are: Australia; Belgium; Canada; Denmark; France; Germany; Hong Kong; Ireland; Italy; Japan; The Netherlands; Spain; Switzerland; United Kingdom; United States.

What it helps you to do

• Allows you to compare the treatment of key tax issues by various jurisdictions – and alerts you to opportunities
• Enables you to tap into a network of tax experts and draw upon their knowledge of their particular jurisdictions
• Over time the Forum builds into a uniquely detailed reference service on each of the 15 countries covered, giving you valuable technical data

Topics Covered Include

• Cross-Border Tax Arbitrage
• E-Commerce Trading Vehicles
• Inbound Electronic Commerce Activities
• Availability of Treaty Benefits for Payments to Hybrid Entities
• Host Country Taxation of Specialised Problems in International Commerce
• Global Equity Plans
• Host Country Tax-Advantaged Investments for Country X Pooled Investment Vehicles
• Differences in Host Country Tax Consequences from Inbound Inter-branch Versus Inbound Inter-company Transactions
• Availability of Foreign Tax Credits (or Deductions) to Host Country Branch Taxpayer and Host Country Company Taxpayer
• Host Country Tax Consequences of Engaging in a Sale-Repurchase Transaction Using Host Country Securities
• Inbound Investments in Securities Backed by Host Country-based Debt Obligations and Receivables
• Host Country Rules Pertaining to Positions Taken by a Taxpayer in Computing Host Country Income Tax Liability
• Global Equity Plans in a Declining Market
• Tax Planning for Cyclical or Other Temporary losses
• Tax Planning for Debt Restructuring
• The Deductibility of Interest Paid by a Domestic Subsidiary to its Foreign Partner Corporation; and to Third Parties on Debt Guaranteed by its Foreign Partner Corporation
• Procedural Aspects of Filing, Guidance, Assessment, Verification and Tax Collection

Comparative discussion of key international tax issues.