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9/2/2013 - 9/2/2013http://www.ibfd.org/Courses/Transfer-Pricing-and-Intangibles#tab_programPRACTICAL APPLICATION OF THESTATUTORY RESIDENCE TESTIBCCORPORATE TAX REFORMTolleyConferencesVenue: Halsbury House. 35 Chancery Lane, LondonWC2A 1EL, UKKey speakers: TBA9/12/2013 - 9/12/2013http://www.conferencesandtraining.com/en/Browse-Events/tax-conferences/Corporate-Tax-Reform/Venue: Millennium Gloucester Hotel, 4-18 HarringtonGardens, Harrington Gardens, LondonKey speakers: Emma Chamberlain (Pump CourtTax Chambers), Patrick Way (Gray's Inn Tax Chambers),Peter Vaines (Squire Sanders), Keith Gordon(Atlas Chambers), among numerous others9/12/2013 - 9/12/2013http://www.iiribcfinance.com/download/send-file/iddownload/987188
IN THE COURTSISSUE 30 | JUNE 6, 2013THE AMERICASCanadaThe Supreme Court of Canada heard an appeal from acompany, DMI, that had sold two forest tenures, withboth sales agreements imparting upon the purchaserthe obligation to reforest the areas harvested. TheRevenue however assessed the company for the taxon the costs of reforestation under national law. Thecompany brought the issue to the Tax Court, whichstated that the reforestation obligation had been a partof the transaction and was included in the price paidby the purchaser. However, the Court ruled that thecompany was obliged to include in its proceeds theestimated cost of reforestation after 12 months followingthe sale, plus 20 percent of the remaining amount.The Federal Court of Appeal disagreed with thispoint and decided that the company should havebeen responsible for the entire estimated cost of reforestation,given that the amount was the valueincluded in the sales agreement. Likewise, becausea value was not agreed upon in the second sale, theCourt of Appeal recommended that the matter beconsidered again by the Tax Court.A listing of key international tax cases in thelast 30 daysgovernment to sell its forest tenures, and that to begranted permission the purchaser had to assumethe reforestation liability. Therefore the obligationwas tied to the sale of the tenures as a future expenserather than being separately included in theagreement, and the Supreme Court rejected theargument "that the purchasers' assumption of thereforestation obligations had to be added to DMI'sproceeds of disposition for income tax purposes."Th e Supreme Court was to consider whether thereforestation obligation was included in the pricepaid for the forest tenure, and if any meaning wasto be given to the specific value included in thefirst sales agreement. It pointed out that the companyhad to obtain permission from the provincialThe judgment was delivered on May 23, 2013.http://scc.lexum.org/decisia-scc-csc/scc-csc/scccsc/en/item/13071/index.doSupreme Court: Daishowa-Marubeni InternationalLtd. v. The Queen (SCC 29)89
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GLOBAL TAX WEEKLYa closer lookISSUE
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GLOBAL TAX WEEKLYa closer lookISSUE
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FEATURED ARTICLESISSUE 30 | JUNE 6,
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taxation treaties concluded by Swit
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UK, its offshore dependencies, and
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financing and all forms of financia
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Th e Government pointed out in part
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Talks are now underway. The TIEA wi
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through which they can clamber in o
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fi nally, and most egregiously, the
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office space, or own tangible asset
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extended for 2 years in December 20
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Financial transactions ( e.g. inter
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OECD Section E - Redraft On Safe Ha
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suggests that the following items m
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Page 37 and 38: State Interest And IntangibleExpens
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Page 41 and 42: Code Sec. 1563(controlledgroup)Stat
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Page 51 and 52: Recurring IssuesRestructuring of th
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Page 61 and 62: NEWS ROUND-UP: COUNTRY FOCUS - ITAL
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Page 65 and 66: ates - such that, in 2014, the 4 pe
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Page 71 and 72: Finally, the Federal Council veheme
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Page 79 and 80: Key speakers: John Capasso (Alvarez
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Page 83 and 84: 6/14/2013 - 6/14/2013http://www.con
Page 85 and 86: THE CYPRUS BAIL-OUT ANDFOREIGN CLIE
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Page 93 and 94: deduct VAT as a result of incomplet
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Page 97 and 98: een paid in the destination State.
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