ARCHIVE - 4 JANUARY 2010

• Documentation requirements included in Japanese reform proposals

  The Japanese government released an outline of its proposal for a 2010 tax reform package on December 22 2009, which is expected to be followed by the 2010 amended tax laws within a few months. January 07, 2010

• Documentation translation gets make-over

  A new software product could revolutionise the often lengthy and expensive process of translating transfer pricing documentation. January 07, 2010

• US extends rules permitting short term loans from foreign subsidiaries

  The end of the year brought some good news for US taxpayers struggling with liquidity issues after the tax authorities announced they were extending for another taxable year the liberalised rules that permit a foreign subsidiary to make short-term loans to its US parent. January 07, 2010

• Crown appeals General Electric decision

  On January 4 2010, the Crown deposited its notice of appeal with the Federal Court of Appeal to the judgment of the Tax Court of Canada issued on December 4 2009 in the case of General Electric Capital Canada Inc v The Queen. January 07, 2010

• Vote now in transactional and planning polls

  In 2010, International Tax Review is running its third annual online polls of the leading tax transactional and planning advisory firms around the world January 07, 2010

• What is in store for transfer pricing recruitment in 2010?

  As a new decade approaches, Aaron Leslie and Liz Tookey of TP International discuss what can be expected from world markets and the demand for transfer pricing specialists. January 06, 2010

• Woodruff leaves KPMG

  John Woodruff joins Gardere Wynne Sewell as a partner in the tax practice group in the Houston office. January 06, 2010

• Indian tribunal rules on importance of comparable data

  A recent Indian tribunal ruling has emphasised the importance of using comparable data for the purpose of benchmarking controlled transactions. January 06, 2010

• Google should expect investigation over UK avoidance, says specialist

  Google, the internet search and software company, should expect an investigation from the UK tax authorities after it used transfer pricing to avoid corporation tax, a leading specialist has said. January 06, 2010

• Nortel uses funding agreement to settle IRS claim

  Bankrupt multinational telecommunications equipment manufacturer, Nortel Networks Corporation, has announced that it has entered into a final Canadian Funding and Settlement Agreement that includes the resolution of a transfer pricing dispute with the Internal Revenue Service in the US. January 06, 2010

• India liberalises foreign technology agreements

  The Indian government has issued Press Note number 8, modifying the foreign technology agreement/collaboration policy wherein all payments towards royalties, lump-sum fees for transfer of technology and payments for the use of trademarks or brand names will be allowed to be paid without any restrictions. January 04, 2010