Exemption Tax

List of top consulting firms 2012

2011-12-16T07:58:00.000-08:00

Following is a list of the top consulting firms around the world with such details as ranking, company name, website url, headquarters, year founded, approximate number of employees, male to female ratio, and other statistics. Being a top consulting firm do not means always prestige and do not bring quality and values automatically, but clients and job seekers of the consulting profession may be interested by these statistics.

Purpose: To summarize and provide beneficial statistical information about the consulting industry and provide quick access gateway to a list of the top consulting companies and websites.
Serving: Researchers, students, professionals, job seekers in the consulting industry and all who seek information about top consulting companies.

Disclaimer: We are not claiming any rights, responsibilites or ownership pertaining to creating, developing, designing, or programming any of the websites listed on this page. All websites listed on this page are publically available for viewing on the internet.

Rankings: Any ranking information regarding the listings above have been made by 3rd parties, organizations which make their ranking info available on public viewable pages free of charge. For this particular listing we have gathered inforamtion from various sources on the internet, including, cnn.com, vault.com, fortune.com and linkedin.com.

The 2011 Best Firms to Work For (according to Consulting Magazine):

The Best Consulting Firms to Work For 2011

Bain & Company
The Boston Consulting Group
North Highland
Point B
Deloitte Consulting
Slalom Consulting
McKinsey & Company
PwC
Booz Allen Hamilton
Huron Consulting Group
Ernst & Young
Accenture
Crowe Horwath
Monitor
A.T. Kearney

The Best Small Consulting Firms to Work For 2011

Stroud Consulting
Impact Advisors
Cask
Vynamic
Infinitive
Fitzgerald Analytics
Lenati
Jabian Consulting
PeopleFirm
HiSoft (formerly Nouveon)
Plus Consulting
Meridian Compensation Partners
Marakon
SEI
IBB Consulting Group

Rank	Consulting Firms	HQ	Industry	Type	# of employees	Year founded	Med age	Male	Fe- male
1	McKinsey & Company	Greater New York City Area	Management Consulting	Partnership	15000	1926	29	67%	33%
2	The Boston Consulting Group, Inc	Greater Boston Area	Management Consulting	Partnership	6000	1963	28	67%	33%
3	Bain & Company	Greater Boston Area	Management Consulting	Privately Held	10000	1973	28	65%	35%
4	Booz & Company	Washington DC Metro Area	Management Consulting	Privately Held	22000	1914	32	64%	36%
5	Deloitte Consulting LLP	Greater New York City Area	Financial Services	Partnership	168000	-	29	61%	39%
6	Monitor Group	Greater Boston Area	Management Consulting	Privately Held	1500	1983	29	63%	37%
7	PricewaterhouseCoopers LLP	Greater New York City Area	Accounting	Partnership	17500	-	29	59%	41%
8	Mercer LLC	Greater New York City Area	Human Resources	Public	18000	1937	34	51%	49%
9	Ernst & Young LLP	Greater New York City Area	Accounting	Partnership	144000	-	29	59%	41%
10	Oliver Wyman	Greater New York City Area	Management Consulting	Public	1001	-	30	70%	30%
11	Accenture	Greater Chicago Area	Management Consulting	Public	177000	1989	30	67%	33%
12	IBM Global Business Services	Greater New York City Area	Information Technology and Services	Public	300000	1911	34	76%	24%
13	KPMG LLP	Amsterdam Area, Netherlands	Accounting	Partnership	137000	-	30	60%	40%
14	Towers Watson	Greater Philadelphia Area	Management Consulting	Privately Held	6400	1934	34	52%	48%
15	AlixPartners, LLP	Greater Detroit Area	Management Consulting	Privately Held	900	1981	35	77%	23%
16	A.T. Kearney	Greater Chicago Area	Management Consulting	Partnership	2700	1926	30	68%	32%
17	Braxton Consulting	Eurpe & Latin America	Management Consulting	Privately Held	250	1996	31	54%	46%
18	The Parthenon Group	Greater Boston Area	Management Consulting	Privately Held	200	1999	28	62%	38%
19	Towers Watson	-	Financial Services	Public	14000	-	34	53%	47%
20	L.E.K. Consulting	London, UK	Management Consulting	Partnership	900	1983	28	70%	30%
21	FTI Consulting, Inc.	Washington DC Metro Area	Management Consulting	Public	3500	1982	32	71%	29%
22	Alvarez & Marsal	Greater New York City Area	Management Consulting	Privately Held	1600	1983	33	73%	27%
23	NERA Economic Consulting	Greater New York City Area	Management Consulting	Public	600	1961	27	61%	39%
24	Capgemini	Paris Area, France	Information Technology and Services	Privately Held	91000	1967	32	77%	23%
25	Navigant Consulting, Inc.	Greater Chicago Area	Management Consulting	Public	2500	1983	32	62%	38%
26	Huron Consulting Group	Greater Chicago Area	Management Consulting	Public	2000	2002	30	61%	39%
27	Hewitt Associates	Greater Chicago Area	Outsourcing/Offshoring	Public	25000	1940	32	55%	45%
28	Roland Berger Strategy Consultants	-	Management Consulting	Partnership	2100	1967	28	72%	28%
29	ZS Associates	Greater Chicago Area	Management Consulting	Privately Held	1400	1983	27	72%	28%
30	CRA International, Inc.	Greater Boston Area	Management Consulting	Public	800	1965	33	65%	35%
31	Arthur D. Little	Paris Area, France	Management Consulting	Privately Held	1000	-	30	75%	25%
32	Kurt Salmon Associates	Greater Atlanta Area	Management Consulting	Public	700	1935	33	63%	37%
33	LECG	San Francisco Bay Area	Management Consulting	Public	1200	1988	34	69%	31%
34	Gallup Consulting	District of Columbia	Management Consulting	Privately Held	2000	-	27	60%	40%
35	Aon Consulting Worldwide	Greater Chicago Area	Management Consulting	Public	6300	1983	36	52%	48%
36	BraxtonTechnology	Europe, Asia & Latin America	Technology Consulting & Services	Privately Held	219	2005	26	74%	26%
37	Cornerstone Research	San Francisco Bay Area	Legal Services	Privately Held	201	1989	27	61%	39%
38	Corporate Executive Board	Washington DC Metro Area	Management Consulting	Public	2000	1979	28	50%	50%
39	Hay Group	Greater Philadelphia Area	Management Consulting	Privately Held	2600	1943	32	47%	53%
40	Analysis Group, Inc.	Greater Boston Area	Management Consulting	Privately Held	500	1981	30	62%	38%
41	Milliman, Inc	Greater Seattle Area	Insurance	Privately Held	2000	1947	35	62%	38%
42	Zolfo Cooper	Greater New York City Area	Financial Services	Privately Held	75	-	31	67%	33%
43	Mars & Co	-	-	-	-	1979	-	-	-
44	The Advisory Board Company	Washington DC Metro Area	Hospital & Health Care	Public	1000	1979	28	43%	57%
45	Putnam Associates	Greater Boston Area	Management Consulting	Privately Held	50	1988	26	64%	36%
46	First Manhattan Consulting Group	Greater New York City Area	Management Consulting	Privately Held	51	1980	26	76%	24%
47	IMS Health Incorporated	Greater Philadelphia Area	Pharmaceuticals	Public	10000	1954	34	57%	43%
48	Buck Consultants	Greater New York City Area	Human Resources	Public	1900	1916	38	55%	45%
49	Giuliani Partners LLC	Greater New York City Area	Management Consulting	Privately Held	11	2002	45	79%	21%
50	Archstone Consulting	Greater New York City Area	Management Consulting	Privately Held	250	2003	34	63%	37%

Certified Corporations

2011-10-09T02:00:00.000-07:00

A new class of corporation

Certified Corporations are a new type of corporation which uses the power of business to solve social and environmental problems. Corps are unlike traditional businesses because they:

· Meet comprehensive and transparent social and environmental performance standards

· Meet higher legal accountability standards

· Build business constituency for good business

How are companies Certified and Audited as Corporations?

1) To become a Corp, each company must complete a Survey Review with a B Lab staff member to make sure that all answers accurately reflect the intention of the B Ratings System.

2) Adopt the Corporation Legal Framework to bake the mission of the company into its legal DNA.

3) Sign a Term Sheet that makes your certification official.

4) When a company becomes certified, they must submit documentation for approximately 20% of their answers to the B Survey.

5) 10% of B Corporations are audited every year - So in their two-year term, all B Corporations have a one in five chance of being audited. In an audit, B Corporations are asked to validate and prove each of their answers on the B Ratings System and their compliance with the B Corp Legal Framework. Typically, the audit results in a score adjustment. If the score falls below the passing grade of 80, B Lab auditors provide a 90 day cure period to cure with as well as improvement recommendations. If the audit reveals that a company has filled out the B Survey has intentionally misrepresented aspects of their business, the company's B Corporation Certification is publicly revoked.

6) Lastly, all B Corporations are required to submit a copy of their company's governing documents amended with the B Corp Legal Framework.

Are there any tax incentives?

There is currently only one tax incentive available. The City of Philadelphia allows certified B Corporations to qualify for a $4,000 tax break as a way to reward companies engaging in sustainable business practices. Under current rules only 25 companies will be able to receive the tax credit, although the city may expand the program in the future. Look for the trend of tax incentives to increase as B Corporations become more popular.

The following states have already passed B Corporation Legislation: Hawaii, Virginia, Maryland, Vermont & New Jersey. And, the following have B Corporation Legislation in the works: Colorado, New York, North Carolina, Pennsylvania, California & Michigan

Colorado Annual Periodic Reports

2011-10-07T01:50:00.000-07:00

Change in Notification for Colorado Annual Periodic Reports

Starting January 1, 2012 e-mail notification will be the only method of receiving notices of Periodic Report due dates for an entity, renewal due dates for a trade name or trademark registration, or other changes to a record. You are strongly encouraged to sign up for e-mail notification if you would like to receive these notices. Conduct a business search for your company name. After you find your company click on the link near the bottom that states “Subscribe to E-mail Notification Regarding this Record” and follow the instructions. If you do not have a computer or e-mail address, then we recommend maintaining a calendar in order to remember the report requirement.

If you have signed up for the Colorado Business Division’s e-mail notification service, an e-mail notice that a Periodic Report is due will be sent at the beginning of the three-month period for filing the Periodic Report on time. The notice will indicate the last day for filing the Periodic Report on time and will provide instructions for filing the report through the Colorado Secretary of State’s website. The Colorado Secretary of State will continue to mail postcard notices to indicate a Periodic Report is due until January 1, 2012.

Managerial Capacity Barriers

2011-03-16T03:31:00.001-07:00

Support programs for addressing internationalization barriers related with SMEs‟ limited managerial skills and knowledge are also identified in several countries. Examples of such programs include the 18-month export coaching course offered by UbiFrance, the French Agency for International Business Development; the Export Academy provided by Czech Republic; the 6-month Global Company Development Program offered by the Scottish Enterprise (a sub-national initiative); and the export managers‟ forum available to Greek SMEs.

Network/Social Ties and Supply Chain Links

2011-03-14T08:07:00.001-07:00

Network/Social Ties and Supply Chain Links.

A number of recent studies have highlighted the importance of network/social ties and supply chain links in triggering SMEs‟ first internationalization step and extending internationalization processes. Both North American studies particularly reported the stimulating effect on export activity of firms ‟ soft assets, including social and network capital, some of which may have accrued through managers‟ immigrant background and associated links. The study among fish exporters from the Azores Islands, an autonomous Portuguese archipelago in the North Atlantic, some 900 miles from the European mainland, highlighted the importance of family and social ties with emigrant communities in global markets in driving SME internationalization (see Boxes 3 and 4)These include research among American, Australian, Canadian and Portuguese businesses. Kocker and Buhl also observed that taking advantage of collaborative links is a common motive among the firms they investigated across ten OECD countries.
Finally, it is important to mention the value of the linkages back to their birth countries that migrants can bring in arranging exporting opportunities [OECD CFE/SME(2008)5/PART1/REV1].

European Union Direct Taxes

2011-02-09T08:01:00.000-08:00

Permanent Establishment is a vital concept in international taxation. While for direct taxes, it is mainly defined by the OECD Model Convention, the European VAT Directive and its implementing Regulation provide an EU-wide approach for VAT.
Difficulties arise as terminology and definitions in indirect and direct tax diverge. Moreover, countries have implemented and interpreted the EU and OECD rules in a different way, impacting on issues like cross-border reorganisations, transfer pricing, taxation of dividends and interest and royalties, tax residence, temporary and permanent transfer of assets, place of supply and VAT liability.
In both direct and indirect tax, the concept of Permanent Establishment has undergone very recent changes: The 2010 changes to the OECD Model Convention and Commentary, and in particular the new Art. 7, will be adopted in national law, as speakers from the Netherlands and Germany will report. The effect of the new definition on treaties with other countries will also be considered.
Some of this topic is addressed in the new book "European Union Direct Taxes", by the International Tax Professor Salvador Trinxet Llorca.
In indirect tax, the current more important issue is the practical consequences of the adoption of the Regulation implementing the EU VAT Directive in January 2011.

Internationalization

2010-12-20T04:31:00.001-08:00

internationalization and international entrepreneurship among small and medium-sized enterprises (SMEs) has remained a topic of considerable contemporary relevance, principally owing to the observed growth effects of cross-border venturing, and the demonstrated capacity of SMEs to drive economic development at national, regional, and global levels (European Commission, 2007). This realisation was at the heart of the 2007 OECD-APEC study on Removing Barriers to SME Access to International Markets, which provided general findings on the major barriers to SME internationalization as perceived by SMEs and policymakers in OECD and APEC member economies.1 The need to obtain a greater depth of understanding and an updated view of the issues raised by the OECD-APEC study provided a raison d'être for this follow-up project. Other value adding features include the additional focus on motivations for SME internationalization ; the coverage of recently available documentation from economies involved in the OECD enlargement (Chile, Estonia, Israel, Russia, and Slovenia) and enhanced engagement process (Brazil, China, India, Indonesia, and South Africa); and the sub-national and sectoral insights offered on SME internationalization barriers, motivations and support programs.

The specific objectives of OCDE report about SME Internationalisation

2010-12-16T04:42:00.001-08:00

i. To analyse in-depth the most significant barriers to SME internationalisation identified from the 2007 OECD-APEC sponsored research on this theme, with a view to uncovering new insights into the nature of these top barriers;

ii. To review recent work pertaining to factors that drive or motivate the internationalisation of SMEs; and

iii. To develop a deeper understanding of the current programs for SME internationalisation, particularly the specific measures aimed at addressing the top barriers identified.

To ensure a greater depth of understanding on SME internationalisation barriers, this study focused on the top four barriers identified by the OECD-APEC study as being by far and away the most serious impediments to SME internationalisation (see Table 1). These include 1) Shortage of working capital to finance exports; 2) Identifying foreign business opportunities; 3) Limited information to locate/analyse markets; and 4) Inability to contact potential overseas customers. A fifth barrier, „lack of managerial time, skills and knowledge‟, is additionally examined. The reasoning is threefold: one, this reflects the importance of this barrier in the Member Economy survey (see Table 2); two, the consistently highlighted primacy of managerial factors in previous relevant global surveys; and three, the widely acknowledged importance of skilled human resources in all areas of economic activity, including market innovation.

To provide an updated appreciation of pertinent aspects of SME internationalisation, the report reviewed the post OECD-APEC survey evidence on the top barriers, drivers and support programs across OECD and APEC member economies and other economies involved in the OECD enlargement and enhanced engagement processes. This has yielded important longitudinal insights, thereby indicating that support programs are appropriately focused on the most resilient and enduring of the factors affecting SME internationalisation.

Knowledge is power

2010-12-09T04:11:00.001-08:00

According to Kotler, the requirements of many customers have changed as a result of the financial crisis. Former knowledge about customers is no longer valid; customers and their needs have to be re-examined.

"YOU CANNOT NOT COMMUNICATE"

In these times where social media prevail, everything a company says must be true and clear. Many service providers ignore this aspect—and will get stung. For example, the US website airlinemeals.net, replete with thousands of evaluations and photos of in-flight food, has already repudiated a fair number of advertising promises.

"BUILDING MEANINGFUL RELATIONSHIPS"

Based in France, Targobank demonstrates that the crisis can be a learning experience. Its bank consultants are subject to pay cuts if they give customers investment recommendations outside of a risk category previously set by the customer. So how does marketing even remain responsive during times of never-ending turbulence? According to Kotler, having one "script" for bull markets and one for bear markets is no longer sufficient. "Companies often get into trouble if they don't have an early-warning system in place. They see the warning signs but don't counter them." How does one set up an early-warning system?

In Chaotics, Kotler mentions two suitable methods: scenario planning and flexible budgeting. In other words, smart marketing managers create the ability to expect the unexpected. And they have flexible response systems. Take Regal Entertainment, for example, which is the biggest movie theater chain in the US. It continually monitors attendance figures for individual movies—should the figures decline, it immediately stops showing the movie in question. Their reasoning is that an outdated offer will not draw anyone in and will show that a company does not know its customers—and that could result in losing their trust.

Proposta da Comissão

2010-12-01T04:33:00.001-08:00

O objectivo da proposta consiste em estabelecer um procedimento que permita à Comunidade avaliar se existe um interesse comunitário suficiente para concluir acordos bilaterais propostos com países terceiros e, na ausência do mesmo, autorizar os Estados-Membros a concluírem estes acordos com países terceiros em certos domínios da cooperação judiciária em materia civil e comercial que são da competência exclusiva da Comunidade.

Uma vez que a autorização concedida aos Estados-Membros constitui uma derrogação à regra segundo a qual a Comunidade tem competência exclusiva para concluir acordos internacionais sobre estas matérias, o procedimento deve ser considerado uma medida excepcional e ter um âmbito de aplicação e uma duração limitados.

Propõe-se limitar o procedimento em causa às questões sectoriais relacionadas com as matérias matrimoniais, a responsabilidade parental e de obrigações de alimentos, por um lado, e com a lei aplicável às obrigações contratuais e extracontratuais, por outro. A proposta em anexo diz respeito ao segundo domínio.

A Comissão propõe as garantias a seguir descritas com o objectivo de preservar o acervo comunitário, incluindo a integridade do sistema comunitário no domínio em causa.

O procedimento baseia-se na notificação prévia do projecto de acordo pelos Estados-Membros que pretendem obter uma autorização para renegociar e concluir um acordó com um país terceiro com base em condições específicas a avaliar caso a caso.

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Behavioral marketing by International Lawyers

2010-12-01T04:27:00.001-08:00

EXTERNAL AND INTERNAL COMMUNICATIONS BELONG TOGETHER

When Starting a business behavioral marketing also fosters a worldwide exchange of information internally as experienced by International Lawyers. Knowledge of global events and issues is only useful to customers if it is available around the world. When it comes to efficient marketing, Freshfields combines specialization with the advantages inherent in a large-scale company. For example, one of its objectives is to represent clients who were acquired in the finance or corporate sectors in the labor law area, too. Cross-selling is also used as a marketing support tool—if cases span sectors, Freshfields will offer a price discount. Clear positioning is necessary and becomes all the more difficult as more companies seek it. And this dictum applies to Freshfields and its competitors as it does to every service industry. "There's no sense in sprucing up a commercial if you're putting out the same message as your competitors," says Kotler. In other words, "focus" will be the buzzword in future, particularly within the service sector. Looking at seemingly straightforward services, two-way communications (preferably demand-oriented) with the customer are becoming more significant, and that extends all the way to complaint management. The Pizza Hut franchise chain, for example, prints its hotline number on every pizza box to take calls from unsatisfied customers. The franchise manager then has 48 hours to resolve the problem. The luxury-hotel chain Hyatt is also known for its fast response times to customer complaints— you can even send them to management using the in-room television and its remote control.

DOES DEMARKETING CREATE A NEW SENSE OF TRUST?

For Kotler, such trust-enhancing measures are just a small part of the imminent marketing revolution. "We want to develop methods that will actually reduce an otherwise continually increasing demand," is Kotler's position, which is surprising from a marketing perspective. The essence of this approach is to perceive "demarketing" as a source of trust. According to this notion, keeping certain types of customers away from your product may actually be a positive marketing approach. One might be inclined to think that this attitude is naïve. But that's not necessarily so, says Kotler, although it does have to be grasped properly in-house. "First, one has to identify values. And then one has to hire people who believe in these values and embody them." Crises always represent crucial tests for Kotler's value-based marketing. For example, in difficult times, how do companies deal with clients that are late with payments? John Deere, the US-based agricultural equipment manufacturer, may serve as a role model, he says. "John Deere helped farmers, while rival International Harvester unceremoniously seized its machines." John Deere's level of generosity is rarely found among service providers, even though times of crisis are a perfect opportunity to create new customer loyalty. Kotler recommends to banks and insurance companies in particular that they fully understand the acute problems some of their customers may be facing. He also thinks that their advertising requires a different tone. "The financial crisis compelled many service providers to rethink their marketing and advertising strategies." Solidarity is the new mantra, he says. For example, Morgan Stanley's European advertisements promote their high equity ratio compared with other banks. "They're probably doing the right thing," Kotler explains "Especially if other banks have to address some rather uncomfortable questions on this point."

IT'S EASIER TO SEPARATE THE GOOD GUYS FROM THE BAD GUYS

These questions are certainly being asked, not just in the industry but publicly as well when starting a business. The growth of social media makes companies an ongoing subject of debate. Internet portals where consumers can discuss their experiences make it "easy these days to differentiate the good guys from the bad guys." From a marketing perspective, turbulent times are actually good times, according to the tenor of Kotler's new book Chaotics. "Ryanair is an example that says a few things about seizing an opportunity that arose from the crisis," he states. During the crisis, Ryanair ran a massive advertising campaign and thereby tapped customers' magnified price consciousness. The outcome was a substantial gain in market share.

KOTLER'S "KEY" POINTERS FOR SERVICE MARKETING MANAGERS. "QUALITY IS KING"

Nowadays, customers have precise expectations of services they utilize. Social media platforms such as Facebook increase transparency, which means customers now define quality.

"BUILDING THE MARKETING ORGANIZATION"

Building up long-term customer relationships is more difficult today than ever before. Customers are fickle. Marketing must quickly adjust to new situations and therefore needs to have, first and foremost, a very flexible organization.

"THE FIRM CAN'T BE ALL THINGS TO ALL PEOPLE"

Opportunities for service companies to differentiate themselves from one another are on the rise. They can be socially oriented or maintain higher environmental standards than their competitors. It's all about accessibility. The physical presence remains irreplaceable. For example, online banks in Europe are currently setting up "finance lounges" in major cities.

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Dividends from Spain to UK

2010-11-26T02:58:00.001-08:00

Dividends from Spain to UK

The Spanish tax deducted from dividends paid by a Spanish Company at the agreement rate of 15 per cent (10 per cent where the recipient is a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Spanish company - but see the final paragraph below) qualifies for credit as a direct tax. A reduction to the above rates is not given where the dividend is effectively connected with a business carried on by the recipient through a permanent establishment in Spain.

Where the recipient of the dividend is a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Spanish company paying the dividend, relief is also due for the underlying tax.

Although the agreement provides a 10 per cent rate of source state taxation in respect of direct investors, the EC Parent and Subsidiary Directive bars the imposition of withholding taxes on dividends paid by a company resident in one Member State of the Community to a company resident in another Member State, where the company receiving the dividend holds a minimum of 25 per cent of the capital of the company paying the dividend. The level of capital required to obtain the 0% rate is reduced to 20 per cent from 1 January 2005, 15% from 1 January 2007 and 10% from 1 January 2009.

The Directive overrides any provision made for withholding tax in the relevant bilateral treaty

Accrued and capitalised interest

2010-11-25T02:25:00.001-08:00

Accrued and capitalised interest

Some news about wealth and asset protection. According to the Savings Directive, "Savings income is also regarded as paid for the purposes of the regulations when a money debt is sold to a paying agent (or a receiving agent) or redeemed by the debtor. Interest added to an account with a bank or building society when the account is closed is interest in the normal way and treated as such under the regulations. However, accrued interest, premiums and discounts paid out at the redemption of securities by the issuer, or included in part of the price paid by a third party purchaser at sale before redemption are also savings income for the purposes of the regulations.

UK market makers who purchase interest–bearing securities from relevant payees or residual entities in prescribed territories or UK agents acting for the seller (e.g. stockbrokers) could therefore be paying agents for the purposes of these regulations. This could be the case even if they are not the paying agent in respect of the coupon payments made to the relevant payee or residual entity selling the securities.

Accrued or capitalised interest normally only arises if:

• a security is sold to the paying agent cum dividend (with an entitlement to the next coupon payment) - in those circumstances the price will include an amount of accrued interest for the period from the last coupon payment date to the date of transfer of the security

• it was a purchased by the seller at a discount, or

• the sale price includes, or takes account of, a premium that is paid on redemption by the issuer.

There is no reportable savings income payment when an interest–bearing security is purchased by a relevant payee or residual entity in a prescribed territory.

If the security is purchased ex dividend (without an entitlement to the next coupon payment), there will not normally be any accrued interest in the selling price and so there may be no reportable savings income. The next coupon payment to the relevant payee or residual entity may, of course, be reportable in the normal way under the regulations by the appropriate paying agent.

('repo') agreements do not give rise to reportable savings income (and manufactured payments which are representative of interest on such debts are also not reportable savings income - see paragraph 89). But a money debt which is acquired by a relevant payee or residual entity under a stock loan or repo agreement may give rise to savings income if the debt is sold, or if interest on the debt is received, by the relevant payee or residual entity during the term of the agreement.

For accrued or capitalised interest you may report either the amount of the savings income or the full amount of the proceeds of the sale or redemption of the securities. You may rely on information from established information vendors in order to determine the savings income realised on sale or redemption."

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“Home country” rule

2010-11-24T03:08:00.001-08:00

"Home country" rule

According to the Savings Directive "You may, if you wish, determine whether or not a fund has exceeded a threshold, or the amount of savings income to report in accordance with the "home country" rule. This means that, for a fund established in a prescribed or relevant territory, or one of the five other territories (not prescribed in Appendix 1), this determination is done in accordance with the rules set by the territory in which the fund is established. You may also rely, as provided in paragraph 123, on information provided on this basis by recognized industry sources."

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Advantage of Cash shells in the Plus Market Exchange in London

2010-11-23T02:50:00.001-08:00

Guidance Notes vs. 5 - draft vs. 8 - cleaned up version

Advantage of Cash shells in the Plus Market Exchange in London

Reversing into a cash shell saves management time in accessing capital.

They also often come with established boards, cash resources and good contacts with institutional investors.

For shareholders of the shell company, a reverse is a way to invest in the target before it attracts a premium to its share price for its quote, while the target gains the benefit of a listing and any cash the shell may have in the bank.

Moreover a readymade shareholder base can assist creating liquidity in the company‟s shares and can provide an excellent source of future funding.

Not all are attractive

Not all cash shells appear to offer attractive prospects.

The money in shells often appears insufficient; others may have liabilities, financial or otherwise.

Guidance Notes vs. 5 - draft vs. 8 - cleaned up version

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The big questions for many managers: Should you get off the plane?

2010-11-22T01:55:00.001-08:00

In some cases, these risks can impact the subsidiary organization's directors, officers and managers. In others, executives from the home territory may be at risk: Some have even been known to question if they should get off the plane in countries in which their company's subsidiary may be involved in a legal tangle, she says. To avoid potential problems, Colwell tells executives to consider D&O coverage for offshore subsidiaries placed by the corporate headquarters, or as local laws require, placed in the subsidiary's country. An important consideration for buyers is to make sure the company's D&O broker has access to partner brokers abroad. "We need insurance policies and programs that can adapt to various indemnification scenarios, so that individuals are protected in all jurisdictions." Hartmut Mai, the Global Head of Financial Lines at Allianz Global Corporate & Specialty, a major provider of D&O insurance, says policies used to have global reach but are now increasingly subject to local regulations. He recommends one-stop shopping for D&O coverage at larger insurance providers that can meet needs in all territories and advise on peculiarities. Mai also advises that managers who are trying to steer their company's D&O program insist on close contact with insurers to foster a mutual understanding of risk exposure. "Keeping in constant communication is not just good for underwriters, it's also good for the client because the client begins to understand how the underwriter thinks and what he is looking for in the risk assessment process," says Mai. David Walters, who manages the commercial D&O business of Chartis Insurance in the UK and Ireland, a part of the former AIG and one of the world's largest D&O insurers, also recommends that companies communicate frequently with their insurance brokers and insurers about business developments that could potentially change a company's risk profile.

According to Walters, companies should treat their D&O providers just like one of their stockholders—and for good reason: "At the point of crisis, if the communication has been two-way and open, a solid relationship would be in place to back up the claims process."

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REVERSE TAKEOVERS IN THE PLUS MARKET (LONDON)

2010-11-19T00:35:00.001-08:00

Greener House Investments Plc also recently completed a reverse takeover, acquiring Fresh T Limited, a privately owned company specialising in Software as a Service.

Following the reverse takeover, the enlarged group was renamed

FreshTL Plc was readmitted to the PLUS markets.

Hanseatic & Baltic Properties Plc

was suspended from the PLUS markets in January 2010 in anticipation of a reverse takeover of United Sino, a Libyan property development company. However, the deal was terminated in April citing "Sino were unable to guarantee raising sufficient funds for us to satisfy ourselves that the enlarged group would have had sufficient working capital to carry out the projects." Hanseatic & Baltic Properties Plc has been restored to trading on PLUS.

Award International Holdings plc recently completed a reverse takeover, acquiring a full service digital marketing specialist, Fuse 8, for £5m which will be satisfied by the issue of 10,215,000 consideration shares.

The directors had examined many acquisition opportunities since Award became an investment company and believe that Fuse 8 presented an exciting prospect for existing Shareholders.

Following the reverse takeover, the enlarged company was renamed Fuse 8 Plc and listed on the AIM Market.

more information on:

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http://international-tax-lawyer.blogspot.com/

Clean or dirty Cash Shells in the Plus Market Exchange

2010-11-18T03:43:00.000-08:00

Cash shells can be "clean‟ purpose built with a fresh pool of capital with the aim of finding a project seeking capital to acquire.

Investors in the shell are backing the board to spend their cash wisely and target profitable companies or companies that can achieve capital growth, even though they have not yet secured a deal.

Alternatively, they can be "dirty‟ companies with a stock market quote and some funds whose previous business failed and have undergone a restructuring and a formal arrangement to eliminate all the company‟ old liabilities.

More about the Plus Market Exchange on:

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http://foreign-tax.blogspot.com/

Private Foundation in Guarnsey

2010-11-17T01:22:00.001-08:00

Background

Much of Guernsey's economic success over past decades
has been largely due to its adaptability and flexibility to react
to changing market situations and conditions. This
adaptability is no better illustrated than by the Island's
willingness to amend and review legislation to ensure that it
retains its position within the increasingly competitive
market place of international finance and over recent years
there have been many examples of this.

Following the revision of the Guernsey Trust Law - which
was approved by the Guernsey parliament in July this year
and now awaits approval by Privy Counsel - the Island is
now planning to introduce legislation to allow the
establishment of Foundations. This innovation will add a
useful new tool to the Island's current financial product mix
and will help ensure that Guernsey remains able to offer a
highly flexible spectrum of financial services to its global
client base.

The Foundation

Foundations have been created under the laws of other
jurisdictions from as early as 1926 (Liechtenstein). More
recently Panama introduced legislation in 1995, Netherlands
Antilles in 1998 and the Bahamas in 2004. Foundations over
this period have become increasingly popular across the
globe but particularly in civil law jurisdictions where the
concept of the Anglo-Saxon Trust is less well known and not
always wholly understood. In certain situations Foundations
can offer a viable alternative to the trust for commercial
structures, estate planning and for charitable purposes.
Whilst there is no single definition of a Foundation, there are
a number of common features and some interesting
comparisons to be made with trusts and companies alike.

Unlike a trust, a Foundation is a distinct legal entity and has
its own legal personality. It can hold assets, sue (or be sued)
in its own name, may enter into agreements with third
parties but unlike a company it has no shareholders. Since
some Foundations are established for charitable purposes,
they may or may not have beneficiaries.

A Foundation is formed by a Founder (either an individual or
corporate body) who provides the assets to be administered
by the Foundation under contractual rather than fiduciary
principles – giving a degree of comfort to those clients
unfamiliar with equitable principles. Beneficiaries of a
Foundation therefore have contractual rights rather than
proprietary rights in its assets. A key attraction is the ability
for the Foundation to reserve powers to its Founder. A
Founder may retain more control than is usual with a Settlor
of a trust. Commonly reserved powers include those relating
to such issues as investment strategy, the appointment and
removal of beneficiaries or even the power to revoke the
Foundation.

The Potential Guernsey Foundation

It is proposed that a Guernsey Foundation would be
established by Charter and run by a Council responsible for
fulfilling the Foundation's purpose as defined in the Charter
– which would also include the Foundation's name, details
of all Council members its registered office (which would be
in Guernsey) and the Foundation's purpose.
tself may be quite generic - for example "estate planning", or
may be something quite specific. It is envisaged that at least
one member of the Council will be a corporate body. The
Foundation would be entered on the public register however
details of the beneficiaries (if any) would remain confidential
as with a Trust subject only to the pre-existing rules
regarding disclosure in proper cases.

The provision of Council members or administrative services
to Foundations will be, a regulated activity as are trustee
services at present ensuring that the interests of clients and
the reputation of the Bailiwick is upheld.

Over and above the Charter, there will normally be a set of
Rules governing the mode of operation for the Council -
whose members would be subject to duties similar to those
of company directors. Unlike the Charter the Rules would be
a private document and not on the public registry.

It is not proposed that a Guernsey Foundation will be
restricted in terms of the type of assets it can hold. Therefore
whilst it is not envisaged that they will be used for purely
commercial purposes, they will potentially be able to hold
shares in a company carrying on commercial activities.
Filing requirements are likely to be limited to changes in
registered office and Council members and changes to the
Charter all of which would need to be registered immediately
the changes occur. If this is the case it's unlikely that an
annual return be required. The filing of audited financial
statements would be subject to the same exemptions
applicable to Guernsey companies meaning many of them
would fall outside the audit requirement. This will ensure that
pricing can remain competitive.

It is also proposed that the tax treatment of Foundations be
similar to that of Trusts with Guernsey trustees.
A Foundation can also have an Adviser whose role would be
set out in the Foundation Charter and Rules. This is largely
similar to the role of Protector within a Trust structure both
having powers such as to appoint or remove Council
members and beneficiaries, or the Adviser's consent may be
required before the Council carries out certain acts.
It should also be possible for a Guernsey Foundation to
migrate to another jurisdiction if so required and equally for
a Foundation established elsewhere to migrate into the
Island, a long as it fulfils requirements under the Guernsey
legislative framework.

An interesting possibility is to establish structures using both
Foundations and Trusts. Private Trust Companies ("PTCs")
are very much in vogue. These are companies established
for the sole purpose of acting as trustee for one trust or, say,
one family. One issue that often concerns advisers is as to
the identity of those who will own the PTC. Often a purpose
trust is established to hold the shares in the PTC but as
Foundations need not have any beneficiaries it is possible
that they will be used as trustees themselves; a Private Trust
Foundation?

Conclusion
The introduction of Guernsey Foundations will offer the
Island's clients an excellent alternative structure assisting
with wealth management and will provide further choice and
flexibility to the Island's fiduciary sector.
The Foundation combines the flexibility of a trust with the
greater degree of transparency of a company. Given the
ability of a Founder to retain a certain amount of control and
the existing market demand for the Foundation structure
from civil law jurisdictions in particular, the Foundation can
only enhance the Island's competitive position in the market
place.

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Hybrid entities and reverse hybrid entities

2010-11-16T03:34:00.001-08:00

International tax planners often refer to "hybrid entities" and "reverse hybrid entities."

From a U.S. tax perspective, a hybrid entity is an entity that is "fiscally transparent" for U.S. tax purposes but not fiscally transparent for foreign tax purposes. In general, an entity is fiscally transparent if the entity's current year profits are currently taxable to the owners of the entity, regardless of whether the entity made any distributions to its owners during that year.

Partnerships are typically fiscally transparent entities. Corporations are typically not fiscally transparent entities. Limited liability companies and various types of foreign entities may or may not be fiscally transparent.

Flexibility in international tax planning may be accomplished by the use of a foreign entity that is a corporation in its country of origin, but has the ability to check the box and elect its classification under Federal tax rules. This article presents a primer on establishing and planning for the use of such "hybrid" entities.

Final entity classification regulations--the "check-the-box" (CTB) rules issued in December 1996(1)--allow taxpayers to elect to treat most business entities (including foreign business entities) for Federal tax purposes as corporations, partnerships or (if the entity has one member) disregarded entities. While specified foreign business entities are excluded from the elective system and are treated per se as corporations, they are generally limited to publicly traded-type entities (e.g., U.K. PLCs, German AGs and French SAs; a list is contained in Regs. Sec. 301.7701-2(b)(8)). Despite the apparent restrictions imposed by the per se list, typically, at least one entity in any given country is viewed as a corporation under local law, but is eligible to check the box (e.g., the U.K. Limited Company, German GmbH and French SARL). Further, Regs. Sec. 301.7701-2(d)(1) grandfathered certain business entities on the per se list in existence on May 8, 1996, allowing them to retain their previous partnership or branch status. The CTB elective regime replaced the former four-factor approach under Regs. Sec. 301.7701-2 for classifying entities, which was cumbersome to apply and sometimes generated uncertainties, particularly for foreign entities.

The final CTB regulations ushered in a new era of flexibility in international tax planning for U.S. persons. However, IRS actions since the issuance of the final CTB regulations have eroded some of the rules' flexibility. This article will discuss establishing a foreign hybrid under the new CTB regime and planning opportunities.

For Federal tax purposes, taxpayers may elect to treat a foreign business entity as either a corporation or as a flowthrough entity, regardless of the foreign country's classification, if the entity type is not on the per se list. (An entity type on the list is automatically treated as a corporation for Federal tax purposes). Thus, a foreign entity taxable as a corporation in its country of incorporation can choose to be treated as a partnership or a branch for Federal tax purposes; such an entity is generally known as a "hybrid" Conversely, an entity classified as a partnership (or other type of flowthrough entity) in its country of formation or residence can choose to be treated as a corporation for Federal tax purposes; such an entity is generally known as a "reverse hybrid."

A reverse hybrid entity is the "reverse" of a hybrid entity in that the entity is fiscally transparent for foreign tax purposes but not fiscally transparent for U.S. tax purposes. Entities that are treated the same for U.S. and foreign tax purposes are not "hybrid" entities.

The use of domestic reverse hybrids in cross-border financing continues despite the issuance by the Internal Revenue Service (IRS) of regulations designed to shut down abuses in the area. These devices, if structured correctly, may enable taxpayers to enjoy double-dip tax benefits with respect to interest expense and reduced withholding under US income tax treaties.

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Tax Treatries in South America

2009-02-12T20:07:00.000-08:00

Issues related to tax treaties in Argentina

The tax treatment of FX gains and losses under the OECD model tax convention is not completely clear. However, from the OECD commentaries it seems that FX gains are embedded in the capital gains tax.

In ruling 925/2005, the tax authority analysed the following case: an Argentine resident purchased a bond issued by the Austrian government at the beginning of the fiscal year and sold it in the same fiscal year.

For the sake of simplicity and to illustrate the reasoning of the tax authority, we assume that: (a) the Argentine resident purchased the bond at 100 euro (when the exchange rate was 1 euro = 1 peso); (b) the Argentine resident sold the bond at 105 euro (when the exchange rate was 1 euro = 3 pesos). The Argentine resident argued that the difference between the sale price (315 pesos) and the purchase price (100 pesos) was a capital gain exempt from Argentine taxation according to the tax treaty. The income of 215 pesos was exempt, according to the taxpayer.
The tax authority split the transaction and considered that 200 pesos was an FX gain arising from the devaluation of the peso and only 15 pesos was a capital gain arising from the sale of the bond (105 euro - 100 euro = 5 euro at the exchange rate of 1 peso = 3 euro).

The tax authority considered that capital gains arising from the alienation of bonds were exempt in Argentina pursuant to section 13(4) of the treaty, and FX gains were subject to tax in Argentina pursuant to section 7 of the treaty.

To reach this conclusion, the Argentine tax authority held that income arising from FX (even when the bonds are sold) was not covered by section 13(4) of the treaty because the FX gain did not originate in the sale of the bonds. It originated in the fluctuation of Argentine currency against foreign currency; thus the FX gain was generated only in Argentina and not in Austria; consequently, there was no possibility of double taxation.

The classification of business income may be challenged because section 7(7) of the treaty provides that where profits include income which is dealt with separately in other articles of the convention, then the provisions of those articles should not be affected by the provisions of this article. FX gains may be considered as capital gains.

The commentaries of the OECD model mentioned that capital gains due to depreciation of national currency were covered in section 13:

"The article does not distinguish as to the origin of the capital gain. Therefore all capital gains, those accruing over a long term, parallel to a steady improvement in economic conditions, as well as those accruing in a very short period are covered. Also capital gains which are due to depreciation of national currency are covered. It is, of course, left to each State to decide whether or not such gains should be taxed."

It may be objected that, since there is no gain which Austria is entitled to tax because the Argentine devaluation has no impact in that country, the treaty is not applicable. However, it is generally assumed that the country of residence will exempt this tax.28 Furthermore, the commentaries of the OECD model seem to indicate that the issue is not clear only when the foreign exchange gains are not connected with the alienation of assets so when they are connected with the alienation of assets, they should follow the capital gain treatment.

International tax and exemption tax

2004-08-10T22:20:00.000-07:00

International tax and exemption tax

There are several sites which cover International tax and the exemption taxes, like www.tax-international.com and www.braxton-co.com , but this is not the rule in international taxation.

Braxton Tax & Law and the exemption tax

2003-08-10T22:22:00.000-07:00

Braxton Tax & Law and the exemption tax

Braxton Tax & Law and the exemption tax refers to the legal and tax coverage of the exemption taxes in an international context. There are some information available in http://www.braxton-group.com/tax-law/, specially about international tax and law issues.