Australia: Employee share schemes impacted by government Industry Innovation and Competitiveness Agenda

The Government has announced today its “Industry Innovation and Competitiveness Agenda” that is designed to drive growth and jobs in key industries. A key part of the agenda is changes to the taxation treatment of employee share schemes.

The Government has recognised that changes made to the tax treatment of Employee Share Schemes by the previous Labor Government have effectively brought to a halt of the use of employee share schemes by start-up companies. It […]

By |October 16th, 2014|

Japan: Tokyo District Court Allows Tax Saving From Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”).

Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion of the consideration paid to the shareholder is deemed to be a dividend. Further, all or a portion of such deemed dividend will not be […]

By |October 14th, 2014|

United States: New York Tax Insights – Volume 5, Issue 10, October 2014

STATE TRIBUNAL REVERSES ALJ AND ALLOWS COMBINED REPORTING
Just as we went to press, the New York State Tax Appeals Tribunal reversed the decision of an Administrative Law Judge and held that two related companies could file combined reports for the 2007 year, in which the statute had changed to require or permit combined reporting whenever there were substantial intercorporate transactions. Matter of Knowledge Learning Corporation and Kindercare Learning Centers, Inc., DTA Nos. 823962 & […]

By |October 14th, 2014|