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ARTICLES
Japan
Casenote - Withholding Tax on Repo Transactions, and the Tax-Free Treatment of TKs under the Netherlands-Japan Treaty
Edwin T. Whatley, Kazuo Taguchi, Yoshiaki Muto, Rodell Molina and Gabrielle Slattery
pp. 360-362
The authors examine recent court decisions on withholding tax paid with regard to repurchase transactions conducted in overseas markets and on whether income from a silent partnership should be eligible for tax-free treatment under the Netherlands-Japan Tax Treaty.
The Controlled Foreign Corporation Legislation
Akiyuki Asatsuma
pp. 363-371
The author provides a critical analysis and rethink of the Japanese CFC legislation.
Recent Tax Reforms on the Exchange of Information Regime
Kazuya Kajikawa
pp. 372-378
This article focuses on the detailed procedures prescribed by the domestic legislation on the exchange of information, including the tax reforms in 2003 and 2006.
Structuring an Appropriate Transfer Pricing Policy
Peter Meenan and Atsushi Nishimura
pp. 379-385
The authors aim to provide some insight into the most significant aspects of Japanese transfer pricing, including a concluding section on the preparation strategies for transfer pricing documentation and tax audits.
Taxation Aspects of Mergers and Acquisitions
Edwin T. Whatley, Kazuo Taguchi and Gabrielle Slattery
pp. 386-396
This article outlines the key taxation issues facing purchaser and vendor entities in merger and acquisition-type transactions of non-qualified reorganizations.
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Tax Treatment of Leases
Hideharu Tanaka
pp. 397-400
The Japanese tax treatment on lease transactions including the changes made under the 2007 tax reforms is discussed.
Taxation of Trusts and Their Beneficiaries
Eric N. Roose and Takeo Mizutani
pp. 401-407
The authors examine the classification of foreign trusts for tax purposes, tax rules applicable to foreign trusts and their beneficiaries and the international issues concerning the application of tax treaties to foreign trusts.
Taxation of Employee Stock Option Plans
Kazumi Hirai
pp. 408-413
This article addresses the key tax issues arising from the employee stock ownership plans in Japan after the enactment of the new Company Law and the 2006 Tax Reform.
DEVELOPMENTS
Reports on the following: Australia, Bangladesh, China, China/Hong Kong, China/Macau, China/Singapore, Fiji, Hong Kong, India, Indonesia, Kazakhstan, Kazakhstan/Singapore, Malaysia, Nepal, New Zealand, Pakistan, Singapore, Solomon Islands, Taiwan, Thailand, Tonga, Vietnam
CUMULATIVE INDEX
pp. 429-431
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