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December 2006

BUSINESS BRIEF

AGN's Newsletter about tax information and general business issues.

Inside this number.............

  • Australia - International Taxation Arrangements
  • France - Residential property
  • Luxembourg - Double Tax Treaty - France/Luxembourg
  • Spain - New preventive law against tax fraud
  • UK - New tax relief for UK firms
  • EUROPE: Corporate Tax Survey 2007
  • WEST ASIA & AFRICA - Economic Overview
  • US
    • IRS appeals Swallows Holding
    • IRS instructions for changing in interest expense
    • Increased allowance for foreign housing costs
    • Proposed regulations on exclusion of the previously taxed income
    • Guidance issued on residence and source rules for US possessions and territories
    • IRS settles with Glaxo Smithkline in transfer pricing case
    • New user fee for US residency certificates
    • Interest expense deductions for US branches of foreign corporations
    • Proposed regs on Capitalization of tangible assets
    • US and Canada combat cross-border tax avoidance
    • Transfer pricing regulations on services
    • Treatment of foreign persons interests in US REMICs
  • US (continue)
    • Proposed regulation to determine who is considered to pay
      foreign tax for purposes of the US foreign tax credit
    • Everson chairs International Tax Forum, emphasizes enforcement
    • German lower court “look through” US S-Corp
    • Treaty Developments
    • New regulations issued on reporting requirements for transactions between US persons and related foreign corporations and partnerships
    • Proposed regs on withholding for portfolio interest
    • Qualified domestic production activities regulations
    • Proposed regs issued regarding E&P of CFCs under §1248
    • Regulations provide guidance on inversion transactions
    • IRS list of countries with residence waiver for 2005

 
September 2006
 AGN INTERNATIONAL - WORLD CONGRESS 2006

The 11 th Annual International World Congress took place in Montréal, Canada from September 17 th to 20 th , 2006 at the Inter-Continental Montréal Hotel, one of the city's most sort after locations.

There were 183 attendees which included delegates and their wives/companions from all around the globe.  The technical programme included presentations by six external professionals and from four of the AGN Canadian member firms on Canadian Tax Implications for the Non-Resident.

 

The AGN Annual World Congress is an excellent opportunity for the members of the organisation to strengthen relationships between member firms.

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