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ARTICLES
France
2007 Finance Bill and Finance Amendment Bill for 2006: 2007, a Paradoxical Year for Tax Rules
Sophie Marciniak
pp. 34-38
The 2007 Finance Bill and Finance Amendment Bill for 2006 generally provide only slight adjustments to regimes or reforms implemented during past years. Nevertheless, there are noteworthy changes which impact individuals, companies and small businesses.
Germany
ECJ To Rule on Denial of Deduction for Currency Loss on Start-Up Capital Granted to a Foreign Branch
Alexander Born and Michael Kunze
pp. 39-41
The European Court of Justice is expected to issue a decision in the case of Deutsche Shell GmbH v. Finanzamt für Großunternehmen in Hamburg. In that case, the Tax Court of Hamburg considered whether, in computing German tax liability, the denial of a deduction for currency losses on start-up capital granted to a foreign branch, constitutes a violation of the freedom of establishment.
Italy
Tax Provisions Impacting Foreign Investors in 2007 Budget Law and Related Tax Act
Marco Q. Rossi
pp. 42-51
The 2007 Budget Law provides for a new special tax vehicle, namely the real estate investment company. In addition, the Law contains new tax provisions on trusts which are far from comprehensive, but establish important principles on their classification and tax treatment.
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Kazakhstan
Issues Concerning Legal Status of Special Purpose Vehicles
Bakhytzhan Kadyrov
pp. 52-56
To promote rapid innovation of new forms of financing for the real estate sector and the issuance of new debt instruments, the need was seen to adopt a law on the securitization of assets. In this regard, the Law on Securitization, once enacted, will govern the activities of an SPV that is created for conducting one or more securitization transactions.
Mexico
Tax Law Changes Affecting Financial Transactions and Institutions for 2007
Luis M. Liñero, Oscar Ortiz and J. Javier Goyeneche P
On 21 December 2006, the Federal Congress approved the economic package for fiscal year 2007. This article will present a summary of the modifications affecting financial transactions, along with the authors' commentary.
Tax Treatment of Weather Derivatives
As part of a continuing survey, this article considers the tax and accounting treatment of weather derivatives in Australia.
RECENT DEVELOPMENTS
Cayman Islands
Changes to Mutual Funds Law
Anton Joseph
p. 67
United States
Fair Value Option Now Available under New Financial Accounting Standard
Anton Joseph
p. 68
CUMULATIVE INDEX
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