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Sean Foley Landon McGrew The US Tax Court recently issued an opinion, in Highwood Partners v CIR, 133 TC No 1 (2009), holding that an extended six-year statute of limitations period applied to a taxpayer's tax return because the taxpayer failed to separately compute and report its foreign currency gain and loss under section 988 and none of the relevant returns adequately disclosed the nature or amount of the omitted income.

Luis Avello Before January 9 2007, the withholding tax rate applied to services, distinguished between technical assistance and engineering services; and non technical services to determine the tax rate applied. At the time, technical assistance services and engineering services benefited from a lowered withholding tax rate of 20% in comparison with non technical services or non engineering services, which were subject to the general 35% rate. In this sense, the historical interpretation held by the Chilean Internal Revenue Service (SII) regarding technical assistance services was that technical assistance services were technical or professional services that a person with specific knowledge of a science or technique renders throughout a recommendation, report or blueprint (private ruling number 4.587 of 2000).

Jean Marc Gagnon Income tax anti-avoidance measures in Canada are usually initiated by the Canadian federal government. Not this time.

Ramakrishna Sithanen, the vice prime minister, minister of finance and economic empowerment, presented his fifth and last budget speech under the mandate of the present government.

Alke Fiebig Recent events have cast new light on the well-known debate within tax authority circles on the privileges for private equity funds. In the past, there was little reason for foreign funds to fear a German tax authority assumption of residency, as long as they confined their local activities to collecting deposits from German investors. The cash was then transferred abroad and invested under the control of foreign managers. Effectively, the German affiliate merely acted as coordinator, or liaison agent, for local depositors and as an adviser to the foreign fund management on German investment and market conditions. It did not generate business income attributable to the fund as such.

Ingrid Anne Kinden In accordance with the Norwegian Tax Act, dividends distributed by a Norwegian corporation to an entity located in another EEA country are 100% exempt from withholding tax if the recipient "corresponds to" a Norwegian entity that qualifies for an exemption on dividends received from a Norwegian corporation. However, the recipient must meet a substance test by having an "actual establishment" and performing "real economic activities" in its home country.

Taxpayers now have a better chance of a fair hearing in court in Chile after the introduction of an independent body of specialist judges.

House Ways and Means Committee chairman Charles Rangel and Senate Finance Committee chairman Max Baucus have introduced legislation to give the Internal Revenue Service (IRS) greater ability to "detect, deter and discourage offshore tax abuses" involving US taxpayers with foreign assets.

As the global economic downturn looks set to worsen in 2009, the 10 most admired tax directors in North America are open about the challenges their industries face and the strategies they have put in place to cope

Indian internet broadband providers are to find out in two weeks whether aspects of their businesses are taxable