Examining US tax policy with views from advisers on recent US developments, including the view from Washington; increasing burdens on the US tax adviser; and reflections on how US tax policy is made.
Chris Morgan reviews recent developments.
Robert Langston with your refresher guide to the rules.
Clive Tietjen and Alison Lobb review three new discussion drafts published by the OECD.
David Harkness and Robert Sharpe explore potential areas of deficiency in the new CFC rules and their interaction with the Banking Code.
Steve Wade describes the latest proposals.
Carl Mellor provides an overview of issues to consider, with further insight (below) from Peter Cussons and Graham Williams.
Chris Morgan reviews topical developments, including HMRC's new guidance on beneficial ownership in relation to double tax treaty claims.
Jon Hills on establishing whether a company is small, medium or large for the purposes of the UK transfer pricing rules.
The CIOT has welcomed draft legislation introducing a statutory definition of residence for tax purposes. Budget 2012 announced that ‘ordinary residence’ would be abolished from 6 April 2013 but overseas workday relief would be retained and put it on a statutory footing.