On 1 October 2009, the General Department of Taxation issued Official Letter No. 4022/TCT-TNCN ("Letter 4022") clarifying the settlement of cases of personal income tax ("PIT") arising from a transfer of land, where the actual land area as measured for the issue of a land use right certificate is greater than the measurements recorded on the land use document ("Increased Land Area").
On 2 October 2009 the General Department of Tax issued Official Letter No. 4056/TCT-CS clarifying the issue of decisions on exemption and reduction of land rent.
The Thai Revenue Department is advocating for non-juristic bodies of persons to be stripped of their status under the Revenue Code in order to prevent abuse and tax evasion.
Richard Leavy quoted on the recent New York court ruling against Tishman Speyer and BlackRock Realty regarding Stuyvesant Town Peter Cooper Village residential apartment complex. Subscription required.
1 October 2009 – Mayer Brown LLP, a leading global law firm, has been named the winner of the North America Tax Litigation Firm of the Year and the U.S. Tax Court Firm of the Year awards in International Tax Review’s fourth annual Americas Tax Awards. The firm also was a finalist for awards in the Chicago Transfer Pricing Firm of the Year and Chicago Tax Firm of the Year categories.
As we described in our January 28, 2009, Client Update, a majority of a three-judge panel of the Court of Appeals for the First Circuit held that the work product doctrine could protect the schedules and supporting documentation behind a company’s reserve for contingent tax liabilities, known as “tax accrual workpapers,” from IRS discovery. U.S. v. Textron, Inc., 553 F.3d 87 (1st Cir. 2009) (the “panel majority opinion”).
On 19 January 2009, the National Assembly issued Decree No. 05/2009/ND-CP providing detailed regulations and guidelines on the amended Ordinance on Royalties ("Decree 05").
For the past two years, Thailand's tourism industry has been plagued by a number of afflictions including political instability, the global economic crisis and recently the Influenza A (H1N1), all of which have wreaked havoc on the once flourishing industry.
12 June 2009 - Mayer Brown LLP, a leading global law firm, announced today that 124 of its attorneys are ranked in the 2009 edition of Chambers USA: America’s Leading Lawyers for Business, including 32 who achieved top-band ranking or higher in 26 national and/or state categories.
June 4, 2009 - Mayer Brown LLP, a leading global law firm, announced today that the 2009 edition of Legal 500 United States ranks the firm’s practices in 24 categories, including top-tier rankings in five categories.
Bylined article by Astrid Pieron and Charles-Albert Helleputte discusses single-transfer pricing on income tax. This article was first published in the June 2009 issue of International Tax Review; www.internationaltaxreview.com.
On May 27, 2009, the US Court of Appeals for the Ninth Circuit reversed the Tax Court’s 2005 ruling in Xilinx, Inc. v. Commissioner (No. 06-74269, slip op. (9th Cir.)), holding instead that the cost sharing regulations in existence from 1997 through 1999 required that stock options costs be included among the costs that must be shared by participants in cost sharing arrangements. While the IRS secured a victory in its long-running effort to force participants to share stock option costs, it did so at the expense of an express conclusion by the Ninth Circuit that the IRS’s administrative position is contrary to the arm’s length standard.
On May 4, 2009, President Obama and Treasury Secretary Geithner unveiled two components of the Administration’s plan relating to US international tax reform. The first component relates to certain changes to the deferral of foreign earnings and the foreign tax credit rules. The second component generally relates to abusive uses of accounts located in tax havens.
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