IN THIS ISSUE

“Whole Business” Securitizations Of Project Cash Flows | Norton Rose Fulbright

Capital markets financing is less expensive and more flexible than bank finance...

London City Airport Transaction

The London City Airport financing last fall was the first use of “whole business” securitization to finance a project in the United Kingdom. The transaction structure is shown on the next page...

US Congress Edges Closer To Action Against Aggressive Tax Schemes

The US Congress is edging closer to action against corporations that engage in aggressive tax planning. The Senate Finance Committee released a draft bill for comment in late May...

OECD Publishes Blacklist Of Tax Havens

The Organization for Economic Cooperation and Development, or OECD, published a list of 35 tax havens at the end of June...

Changes in law will revive interest in the Netherlands Antilles as a place to put offshore holding companies | Norton Rose Fulbright

Recent changes in law should revive interest in the Netherlands Antilles as a place to put offshore holding companies...

Companies Hoping To Tap Into US Capital Markets Must Comply With Trade Sanctions

Foreign companies may be unable to raise debt or equity in the US capital markets if they have violated US trade sanctions against third countries...

IN OTHER NEWS

Group of utiltiies pressing Congress to allow faster tax depreciation for generating equipment | Norton Rose Fulbright

A GROUP OF UTILITIES IS PRESSING CONGRESS TO ALLOW FASTER TAX DEPRECIATION for generating equipment...

India

India increased the effective tax rate on earnings from Indian projects from 45.27% to 52.03%.

Mauritius companies receive notices from tax authoritiesasserting they do not qualify for benefits under India-Mauritius tax treaty | Norton Rose Fulbright

FIVE MAURITIUS COMPANIES received notices from the Indian tax authorities in March asserting the companies do not qualify for benefits under the India-Mauritius tax treaty...

Bulgaria

Bulgaria unilaterally revoked its tax treaty with Cyprus after discovering that most investment into Bulgaria was being run through Cyprus to avoid withholding taxes.

Tax lawyers discussed strategies for stripping foreign tax credits | Norton Rose Fulbright

TAX LAWYERS DISCUSSED STRATEGIES FOR STRIPPING FOREIGN TAX CREDITS at the American Bar Association meeting in May...

IRS indecision could make it more expensive to interconnect merchant plants to utility grids | Norton Rose Fulbright

IRS INDECISION COULD MAKE IT MORE EXPENSIVE TO INTERCONNECT MERCHANT PLANTS to utility grids...

Holland announces it will no longer issue tax rulings on hybrid instruments or entities | Norton Rose Fulbright

HOLLAND announced that it will no longer issue tax rulings on hybrid instruments or entities...

Saudi Arabia cut taxes on foreign investors | Norton Rose Fulbright

SAUDI ARABIA cut taxes on foreign investors, but details of the reforms have been slow to emerge. The reforms may not be as generous as first thought...

Section 29 tax credits adjusted downward after the US government revamped its inflation index | Norton Rose Fulbright

SECTION 29 TAX CREDITS were adjusted downward April 1 after the US government revamped its inflation index. The section 29 credit is a credit for investing in alternative fuels projects...

Biomass groups lining up behind a bill Senators Lott and Murkowski introduced | Norton Rose Fulbright

BIOMASS GROUPS are lining up behind a bill that Senators Trent Lott (R.-Miss.) and Frank Murkowski (R...

The Colombian Government

The Colombian government proposed reducing the corporate tax rate from 35% to 32%.

Incentives to burn local coal under fire | Norton Rose Fulbright

INCENTIVES TO BURN LOCAL COAL came under fire...

Water utilities lobbying for legislation to clarify that they do not have to report customer connection fees as income | Norton Rose Fulbright

WATER UTILITIES are lobbying Congress for legislation to clarify that the utilities do not have to report customer connection fees as income...

FSCs remain under fire | Norton Rose Fulbright

FOREIGN SALES CORPORATIONS, or FSCs, remain under fire. The European Union rejected a US proposal to allow foreign companies to claim FSC benefits provided they subject themselves to US taxation...

The Czech Republic

The Czech Republic is offering 10-year tax holidays for investments in new projects and five years of partial corporate tax relief for expansions of existing facilities.

The IRS is Studying the Tax Treatment of Certain Partner Conversions

The IRS is studying the tax treatment of certain partner conversions.

Commonwealth Energy arguing that improvements made in the late 80s to a 1960-era power plant qualified for ITCs | Norton Rose Fulbright

COMMONWEALTH ENERGY is arguing that improvements it made in the late 1980’s to a 1960-era power plant qualified for investment tax credits on grounds that it had to make the improvements to perfor...

IRS business plan this year calls for rewriting so-called “true-lease guidelines” | Norton Rose Fulbright

MINOR MEMOS. The IRS business plan this year calls for rewriting so-called “true-lease guidelines” that the agency has used since 1975 . . . ...