Internat Tax Brochure

International tax

Braxton provides business, legal, and financial executives with the expert advice they need to operate successfully in international markets.

Practical European Tax Strategies delivers expert insight into the proven strategies your colleagues are using to minimize their tax liability in the European markets. Every month, Strategies delves into how the region’s tax developments will affect your organization … and what you can do about it right now.

Proven Solutions to Help You Maximize After-Tax Profits for Your International Operations

Practical International Tax Strategies tells you in clear business language how your colleagues at leading companies are reducing their tax burden in international transactions. Subscribers participate in a dialogue of leading practitioners who consider the best strategies for coping with important new tax rulings, regulations and court decisions, originating both from the US and international sources

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Whether you are a private investor or an institutional investor your investments are potentially subject to withholding tax. The vital practical issues surrounding this important tax are explained as well as how it can significantly affect the value of your investments. International Withholding Tax: A Practical Guide to Best Practice and Benchmarking will arm investors and corporations with the knowledge to confront their fund managers, financial advisors and custodians with the essential questions to maintain the integrity of their investments. For investment managers, custodians and financial institutions, this will provide a blueprint for best practice and benchmarking in the area, ensuring they can answer to their clients and shareholders, and maintain their competitive advantage. Interest areas: banking, taxation, investment management, hedge funds, wealth management, private banking.

Only a fraction of all the recoverable tax deducted on cross border investment income is ever reclaimed. With diminishing investment yields and more competitive markets, investors and financial institutions must know enough and do enough to maximise returns on their own and their client’s investments.

International Withholding Tax provides detailed and practical discussions of withholding tax regimes, opportunities for investors and financial institutions, the requirements of and options for tax reclaim procedures, guidance on managing the reclaim process and a detailed discussion of the US, Irish and Japanese Qualified Intermediary regulations.

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A step-by-step guide to planning, documentation, design, structure and analysis of international transfer pricing. Whether you are drafting an agreement or analyzing the most current issues, this treatise should be among your primary resources. Includes the full text of the OECD guidelines, an A-to-Z transactional analysis of the penalties and local administrative procedures.

The use of virtual companies
Documentation of transfer pricing agreements
Alternative dispute resolution procedures
Electronic transactions
Using cost sharing to develop intangible property
Financial product transactions

U.S. International Taxation: Practice & Procedure by Cym H. Lowell and Mark R. Martin

This complete procedural resource provides step-by-step guidance to handling all IRS procedures relating to documentation, compliance and controversy handling for all international tax issues. The presentation is transactional in orientation and supported by factpatterns, and addresses all procedural matters.

U.S. International Transfer Pricing by Cym H. Lowell, Peter L. Briger, and Mark R. Martin

Your guide to principles and strategies that have proven effective in the most important area of international tax. The authors develop the substantive law (some 450 cases and relevant regulations), then apply these principles to: transfer pricing studies, presenting positions in a controversy or litigation context, obtaining advance pricing agreements (APAs) and responding to a summons or examination

Tax Services
■ Expatriate and Migrant Planning
■ Finance and Ownership of
Real Estate Worldwide
■ International Corporate Structuring
■ International Tax Planning of
Cross-border Transactions
■ Managing Foreign Tax
Credit Position
■ Representation in Tax Litigation
■ Transfer Pricing Audits,
Planning, and Compliance
■ VAT Advice on Crossborder
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International tax advisory
We provide advice on international
transactions:
Inbound and outbound investment
Treatment of foreign exchange
differences
Thin capitalisation
Transfer pricing
Permanent establishments
Controlled foreign companies
Foreign tax credits
Double taxation agreements.
Tax is a highly regulated area, carefully
monitored and strictly enforced by the
authorities. In this environment, planning,
implementing and reporting on significant
business transactions is best undertaken
with a clear understanding of the tax
consequences and under the protection
of legal professional privilege.
Our Tax practice provides advice on local
and international corporate tax planning
and transactional work. We are actively
involved in the dispute resolution process
with a number of our client’s disputes
recently being heard in the Tax High Court
and the Supreme Court of Appeal. We
keep you informed of anticipated changes
in law and tax practice to help you manage
and take advantage of any developments
in the tax arena.
INTERNATIONAL TAX COMMITTEE
HLB has a dedicated International Tax Committee comprising of committed international tax experts representing HLB member firms with the core focus on the development of tax services within the network.

We use the the world’s most
comprehensive database currently available on
taxation, with a complete repository
of tax information, practice and analysis.

Issues addressed
include how to minimize international tax liabilities,
protecting global profits and cash flow from
currency fluctuations, and managing financial
resources overseas. Written for legal, financial, and
tax professionals, each WorldTrade Executive report
draws on the expertise of international tax and
finance experts facing these issues throughout the
world.

International Tax Planning Strategies

a transactional
planning tool that integrates rules, planning ideas
and implementation techniques to guide
practitioners through complex transactions

provides specific guidance to tax consequences of transactions occurring in 2012.

Details
The RIA Federal Tax Handbook, 2012 Edition reflects all tax laws enacted up to the time of publication.

The Handbook continues to be the premier source for today’s federal tax law. This year’s book is more extensive than ever, providing you with the precise explanations of tax changes affecting your business. But it’s more than just a comprehensive tax resource written in terms you know and use.

USE THE HANDBOOK AS A VALUED RESOURCE FOR YOUR STAFF!

Put this insightful advice and guidance on the latest tax topics and changes right at your employees’ fingertips. The Handbook offers:

Detailed coverage of the latest tax legislation
Current and future income tax rates, current estate, gift and excise tax rates, and Social Security tax thresholds
Guidance on which forms to use to report transactions
Extensive professional guidance based on the experience of RIA’s expert editorial team
Whether it’s used as a resource for your employees or a quality premium for your clients, the RIA Federal Tax Handbook is the only tax resource for all of your day-to-day tax questions.

Global Transfer Pricing Solutions

Reduce your in-country tax exposure when you build a global business strategy that balances your business goals with sound transfer pricing and tax compliance policies. You’ll find insight into the major worldwide transfer pricing regimes with in-depth analysis of proactive transfer pricing management, e-commerce, intellectual property, and much more.

providing business professionals with guidance in understanding legal and practical conditions for building a global business strategy.

In order to successfully grow a business into a new global market, professionals must be aware of the often complex policies of the local tax authorities or else risk compromising profit margins. Global Transfer Pricing Solutions aids multinationals in navigating transfer pricing and tax compliance policies around the globe by examining critical issues and sharing innovative strategies that will help businesses build an effect transfer pricing policy, while also maintaining an aggressive market strategy.

Articles, written by experienced practitioners of international legal and accounting firms and senior international transfer pricing professionals at the largest multinationals, share expert insights into the major worldwide transfer pricing regimes with in-depth analysis of proactive transfer pricing management.

This one-of-a-kind resource explores key topics such as:

Procedural Aspects: APAs as a Solution to Global Documentation Requirements (DLA Piper LLP)
Adjusting Transfer Pricing to Account for Recent Events Such as Economic Downturn (PricewaterhouseCoopers AG)
Transfer Pricing Beyond the Tax Department (Skadden, Arps, Slate, Meagher & Flom LLP)
Transfer Pricing Audits in China: A Hypothetical Case Study (KPMG)
Holding Company Considerations: Ireland and UK Compared (Smith & Williamson)
Russia’s Proposed Transfer Pricing Law (Ernst & Young)
Regional Trends in Transfer Pricing in Latin America (Baker & McKenzie)
Transfer Pricing in India (Majmudar & Co.)
Transfer Pricing and Recharacterization in Canada: A Closer Look (Gowling Lafleur Henderson LLP)
Mexican Tax Audits (Baker & McKenzie)
Treasury, IRS Publish Section 482 Services Regulations (Ernst & Young)

Tax
STRATEGIC ADVICE ON ALL TAX MATTERS
Gowlings’ National Tax Practice Group provides counsel on a broad range of tax matters:
• Mergers and acquisitions
• In-bound and out-bound cross-border transactions
• Public and private financing
• Financial products, structured finance, lease transactions and securitization
• Transfer pricing
• Corporate tax planning, reorganizations, amalgamations and sales of businesses
• Debt restructuring
• Partnerships and joint ventures
• Executive compensation
• Real estate projects and financing
• Resource taxation
• Indirect tax, harmonized sales tax (HST), goods and services tax (GST), provincial sales tax, and other commodity and customs matters
• Tax planning for businesses and entrepreneurs, including family-owned businesses and succession planning
• Personal and estate planning
• Charities and not-for-profit entities