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The article focuses on the need to overhaul the foreign investment patterns of the U.S. There is no justification for assuming that the investment of capital even in Western Europe necessarily produces any distortion in the economy. But there is no doubt that the exports have been affected by the outflow of capital for investment in manufacturing in Western Europe. On the basis of some evidence gathered by a few American Federation of Labor and Congress of Industrial Organizations affiliated unions, it is clear that exporting of jobs has occurred in women's apparel, men's clothing, and the electrical and typewriter industries. The labor movement has strongly opposed such exporting of jobs and has supported tax policies designed to stem the flow of capital for that purpose. One proposal recommends the immediate application of the full corporate tax on profits earned by the U.S. firms from the sales of products shipped back from their overseas operations, when the overseas corporation receives more than 10% of its total gross revenue from such sales.

The article discusses the developments in the area of taxation in Vietnam as of mid-2013. It claims that the country has signed double taxation agreements (DTA) with over 60 countries in order to eliminate double taxation of international income and promote foreign direct investment. It examines the various official rulings issued by the General Department of Taxation (GDT) concerning such issues related to the so called permanent establishment (PE).

The article discusses the developments in the area of taxation in the U.S. as of mid-2013. It focuses on the private letter ruling (PLR) issued by the Internal Revenue Service (IRS) stating that an inbound reorganisation of a publicly traded non-U.S. company that indirectly own a substantial amount of real property in the country will be exempted from tax. It claims that the taxpayer should comply with the Foreign Investment in Real Property Tax Act (FIRPTA) rules.

The article discusses the implications to businesses of the new Carrez Amendment provision of the tax law in France. The Carrez Amendment limits the tax deduction of a French company's interest expenses incurred in relation to its acquisition of certain shares. The amendment aims to control the tendency of foreign investors to use a French company to purchase shares with the aim of getting complete tax deduction of the interest expenses. The limitation applies to expenses incurred in buying shares considered as titres de participation for tax purposes.

The article explores the impact of tax reforms in Spain on international investments in Spanish real estate assets and debt in 2012. It discusses the need of Spanish banks to raise the coverage of their real-estate risk exposure through provisions and capital buffer. It also assesses the impact on the tax reforms of rules concerning the deductibility of financial expenses by Spanish companies. In addition, the article discusses how foreign investors in Spain can comply with changes in the tax rules.

The article discusses the imposition of tax incentives for foreign investments in Bosnia and Herzegovina. The incentives offer same rights and obligations to both foreign and domestic investors. The government also introduces corporate income tax reduction against a foreign profit tax paid by investors.

The article reports on the finalization of two tax determinations by the Australian Taxation Office (ATO), which are relevant for the taxation of gains made by other non-resident investors. Tax determination (TD) 2011/24 confirms ATO's view that the source of profit derived by a non-resident from the sale of shares in an Australian corporate group, which are acquired by a private equity fund or in a leveraged buy-out, does not depend solely on the location of the execution of the purchase and sale contracts. Moreover, TD 2011/25 confirms the view that a business profits article can apply to a foreign limited partnership (LP)'s Australian sourced business profits, wherein the LP is treated as fiscally transparent in a country where Australia has entered into a double tax agreement (DTA).

The article focuses on the corporate tax in Latin America. It says that the tax rules on foreign direct investment in Colombia will gain attention throughtout 2012 particularly in private equity funds. It mentions that the government in Chile has increased company taxes from 17% to 20% as a temporary solution to increase revenue due to the earthquake damage in 2010 and 2011. It states that taxpayers in Mexico believe that tax policy needs to be reformed in 2012; however the implementation of flat tax results from another year of monitoring and analysis.

The article offers information on the conditions that should be met in order for foreign collective investment vehicles to be exempted from the corporate income tax (CIT) regulations in Poland.

The article discusses the exposure draft legislation relating to the proposed foreign accumulation fund (FAF) rules and the controlled foreign company (CFC) that was released by the government of Australia on February 17, 2011. It says that the draft rules aim to encourage foreign firms to establish regional headquarters in the country and enhance the competitiveness of Australian firms through offshore operations. According to the author, Australian taxpayers investing offshore should be relieved from the difficult compliance procedures related to the CFC and past foreign investment fund (FIF) regimes and from additional Australian tax costs.

The article reports on the release of a copy of an informal ruling request dated November 5, 2009, by the Tokyo Stock Exchange (TSE) which it submitted to the Japanese tax authorities (NTA) requesting confirmation of the tax treatment of foreign investors trading on the TSE through a co-location arrangement. Japanese law does not clarify the issue of whether deals conducted through a servers constitutes a PE in Japan. It is also not clear whether and to what extent foreign investors can depend on the confirmation of the request.

The article reports that the Australian government committed itself to a comprehensive review of Australia's tax system to create a tax structure that positions it to deal with the demographic, social, economic and environmental challenges of the 21st century. The government has quarantined three issues from the review, including the Goods and Services Tax (GST) regime, tax-free superannuation payments for over 60s, and the announced aspirational goals for personal income tax. More recently, the Review of International Tax Arrangements (RITA) reviewed those international tax laws affecting offshore investment, the attraction of capital and related matters.

The article discusses President H. E. Yoweri Museveni of Uganda, who has invited business enterprises in Trinidad and Tobago to invest in and relocate to Africa. Yoweri also said that the markets of nations like the U.S., China, and members of the European Union have allowed African countries entry to those markets without charging them taxes or quotas.

The article reports that in response to the controversies surrounding the Montevideo Treaty, the Attorney of Treasury in Argentina has issued two opinions according to which the most favored nation clause of article 48 of the Montevideo Treaty of 1980 does not grant relief from personal assets tax on interests in Argentine companies held by shareholders located in any member country of the ALADI, the association of 11 Latin American countries.

Outlines the proposed rules for taxing overseas investments and the potential problems that businesses may encounter in New Zealand. Overview of the current rules; Details of how the new rules work; Restrictions imposed to overseas investors.

Reports on the changes made in the controlled foreign companies (CFC) regulation in Great Britain. Exemptions to the CFC provisions; Aims of the first set of regulations according to the Inland Revenue; Effectivity of the second set of regulation.

Discusses the changes to be made in Australia's international tax framework. Reduction of controlled-foreign-company rules; Application of the exclusion from the capital gains tax regime of gains and losses arising from the sale of business subsidiaries to Australian-owned and foreign-owned businesses; Taxation of the sale of interposed entities.

Deals with the proposed Finance Bill in the British Parliament which aims to change the tax treatment for offshore funds in the country. Ruling for the taxation of offshore funds in the country; Proposals under the law for the taxation of offshore funds; Implications of the changes.

Focuses on the Entidad de Tenencia de Valores Extranjeros (ETVE) tax ruling in Spain. Tax treatment for foreign investments under the ETVE; Benefits of the ETVE on foreign companies and subsidiaries; Increase in the number of international investors in the country who use ETVE.

Focuses on the efforts of the Chinese government to combat tax evasion by foreign-invested companies in the country. Plan of the Chinese government to conduct an investigation and transfer pricing audits on foreign-invested companies; Incentives being provided by the government to foreign companies.

Reports on the approval of a new tax bill which reduces the corporate tax rate of foreign investments in the Kingdom of Saudi Arabia as of February 2004. Industries exempted from the new flat rate of tax; Companies that will benefit from the lower tax; Comment from Fathi Abbas, director of tax services at Deloitte & Touche in Riyadh.

Deals with the tax reforms unveiled by Chilean Finance Minister Nicolas Eyzaguirre on April 19, 2001. Goals of the reform; Details on the removal of the 15% capital gains tax paid on the disposal of shares; Plan to reduce the tax that foreign investors pay on the interest from debt; Benefits of the tax reform to the Chilean economy.

Comments on several groups' complaints about the lack of business confidence in New Zealand. Reflection of lack of interest in the facts; Dearth of quality analysis of government policy initiatives; Tax treatment of overseas investors; List of things that a typical European Union employer expects to fork out for; Marginalization of New Zealand in the global economy.

Reports that Saudi Arabia has introduced a set of tax incentives for foreign investors on April 11, 2000. Terms of the tax incentives; Proposed abolition of tax holidays for investors; Factors that were dissuading foreign companies from moving into the country.

Reports that India has reversed its threats to end capital gains exemptions for foreign institutional investors who run funds through the tax haven of Mauritius. Impact of the threats on Indian stock market; Protest of some foreign investors on the proposed removal of exemptions; Tax treaty between Mauritius and India.

Reports that the steel industry in Great Britain is worried that government plans for a climate tax in 2001 could drive foreign investment out of the country. Taxation on companies willing to set up energy-efficiency program in Great Britain; Amount of energy needed to make a ton of steel in Great Britain.

Reports that the decision of Australia's Federal Court in two cases involving companies within Kerry Packer's Consolidated Press Group have provided guidance for Australian taxpayers structuring overseas investments. Two-tier funding structure adopted by Australian companies; Overview of the Tax Act.