Income Tax

List of top consulting firms 2012

2011-12-16T07:58:00.001-08:00

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%

Memoranda is signed in THE DUBAI FINANCIAL CENTER

2011-06-07T05:51:00.000-07:00

Last year the DFSA, after consultation with a panel of market practitioners and experts, made a series of regulatory changes to the DIFC’s Collective Investment Funds regime in order to make the Centre a more attractive investment centre for both international and domestic fund managers. In the third quarter the Carlyle Group became the first company to establish and manage an investment vehicle under the new funds regime.

2010 also saw continued DIFC Authority efforts aimed at supporting dialogue and international co-operation between counterparties, as well as creating strategic partnerships with international jurisdictions thus strengthening the DIFC’s offering to clients. Six Memoranda of Understating (MoUs) were signed in 2010 to bring the total up to 11 MoUs with various jurisdictions. The MoUs signed in 2010 were with Luxembourg, Madrid Centro Financiero, the UAE Ministry of Finance, the Economic Zones World, the Dubai Department of Economic Development and the Dubai Department of Tourism & Commerce Marketing. Meanwhile, the other independent entities under the DIFC umbrella, the DFSA and DIFC Courts, have also both signed a number of different cooperation agreements during 2010.

Over the course of 2010, the DFSA entered into eight new bilateral MoUs and two new multilateral MoUs, bringing the total MoUs signed to date to 56. New bilateral MoU partners include the Qatar Financial Centre Regulatory Authority, Autorité des Marchés Financiers (France), the New York State Banking Department and The Office of the Superintendent of Financial Institutions, Canada. At the same time, the DFSA signed multilateral MoUs with the Asian-Oceanian Standard-Setters Group and International Association of Insurance Supervisors. Meanwhile, the DIFC Courts signed its first international MoU with Jordan in Q2 2010. Adding to its existing MoUs with judicial counterparties from Dubai, Abu Dhabi, and Ras Al Khaima.

“We have already started reaping the rewards of our new business strategy and we are confident that DIFC will continue to play an important role in providing market participants vital support in the rapidly changing business environment in the region” He added.

CEO of DIFC Authority Abdulla Mohammed Al Awar, said: “We are very proud of the growth and success we have achieved on different levels in 2010. There is no doubt that the road ahead remains challenging. Although, we believe that there are still many untapped opportunities that our new strategy will position us to take advantage of.

We are committed to growing our existing client partnerships and we look forward to the continued support and guidance of our clients in our journey together to achieving greater success.”

Governor of DIFC Ahmed Humaid Al Tayer, said: “The solid growth witnessed by DIFC in 2010 reflects the importance of the Centre to financial and business institutions seeking to take advantage of opportunities present in the UAE and the wider region. With its continuous efforts to develop further its modern infrastructure, free zone offering and self-governing laws and courts, DIFC has consolidated its position as the pre-eminent and favoured financial centre in the region."

One-stop-shop

2011-03-22T03:50:00.000-07:00

One-stop-shop
Companies on groups will be able to deal with a single tax administration called principal tax authority, which should be the one belonging to the Member State in which the parent company of the group is resident for tax purposes also called principal taxpayer.
There is also an advance ruling mechanism on the proposal. Audits will be initiated and coordinated by the main tax authority but the tax authorities of any Member State in which a group member is subject to tax may request the initiation of an audit.
All the disputes between tax authorities and taxpayers are dealt with by an administrative body which is competent to hear appeals at first instance in accordance to the law of the Member State of the principal tax authority.

Social Ties Driving Internationalization for SMEs from Azores Islands, Portugal

2011-03-14T08:22:00.001-07:00

Social Ties Driving Internationalization for SMEs from Azores Islands, Portugal

A recent study of a small fish exporter from the Azores Islands, an autonomous Portuguese archipelago in the North Atlantic, some 900 miles from the European mainland, offers useful insights on the key drivers of internationalization for companies based on small islands. It illustrates the critical role of social ties in guiding and supporting island-based SMEs towards successful internationalization. Often challenged by „isolation‟ and distance from the core economies, and by dis-economies of scale and high transportation cost, these SMEs from small islands tend to exhibit relatively low international involvement. The resultant economic weakness associated with such islands often fuels emigration. In the case of the small fish exporter from the Azores Islands investigated by Camara and Simeos (2008), this meant access to major emigrant communities in Canada (British Columbia and Quebec) and the United States (California, Hawaii, Massachusetts, and Rhode Island) among others. There is evidence, however, that some island-based SMEs leverage the network of family and social ties existing between those remaining on the islands and those that emigrated to compete in international markets.
Source: Camara and Simeos (2008)

Growth Motives.

2011-03-14T05:45:00.001-07:00

Growth Motives.

Growth opportunities associated with international markets were identified as a key driver of firm internationalization in several recent studies. Orser et al. (2008), for example, reports say that after allowing for the impacts of firm size and sector, Canadian legal firms whose owners had expressed growth intentions were more than twice as likely to export, than those whose owners did not indicate growth ambitions. Firms‟ overseas venturing decision also seems to be motivated by a need for business growth, profits, an increased market size, a stronger market position, and to reduce dependence on a single or smaller number of markets. The possibility of growth in other markets and increased profit opportunities from international expansion were highlighted as key stimuli for exporting among the Australian, British, Spanish, Swedish, and US firms investigated in recent studies.

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.

OCDE prerrogatives for internationalisation on SME

2010-12-16T04:43:00.001-08:00

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 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.

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.

An opinion from one of our readers commenting the news from Yahoo

2010-12-09T04:13:00.001-08:00

What difference would it make to our standard of living if EVERYONE paid an increase in taxes?. Several people are tired of the argument over tax the rich but not the middle class. Social Security recipients have given up the COLA for two years. Who else in the country has already given up that much? Why not let the Bush tax cuts expire for everyone? Returning taxes to the Clinton era levels might return us to the Clinton era prosperity levels. It is worth a try since nothing we have done since the Clinton era has worked. America has been in decline since he left office.

Another blog where you'll find International Tax information is International Tax Spain

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.

More about the International Lawyers that you will need to start a business on International Lawyers to start a business

Litigation Risk

2010-11-26T03:05:00.001-08:00

Litigation Risk

Despite prudent decisions and the best possible advice, corporate directors face an increase in international legal actions that can impact their personal assets. think:act examines what top managers should look for in corporate D&O (directors and officers) programs.

The Enron scandal of the last decade transformed corporate governance. It also had a lasting effect on the D&O insurance market, given CEO Jeffrey Skilling's legal bills estimated at $23 million: The case piqued interest in the coverage that protects company officers from personal financial liability if they are sued. And, as insurers assessed the riskier business climate, premiums began to rise. Like malpractice insurance for high-level managers, the "directors and officers" insurance forms a worldwide market today, worth $8.8 billion in 2008, and covers top managers in the event of a breach of duty and a resulting lawsuit. Usually reserved for companies with a fair share of assets and management board structures, the pricey insurance policies, with premiums that can reach up to several hundred thousand euros a year for millions in coverage, essentially let individuals hedge the personal financial risks they face by playing in the top league. At the same time, the policies are a tool for making corporate entities responsible for the actions of their employees and protecting corporate assets.

D&O Policy Holders are more likely than ever to be sued.

In the aftermath of the subprime financial crisis, companies as well as their directors are advised to be even more cautious about potential financial liability for their management decisions, says attorney Kevin M. LaCroix, the author of the D&O Diary and a director of OakBridge Insurance Services. That's because D&O policyholders are now more likely to be sued, and more likely to be sued for larger amounts, than in the presubprime era. Whereas class-action lawsuits were once common only in the US, such lawsuits— with their massive potential for financial damage—are gaining popularity outside North America as part of governance reform aimed at securing recourse for shareholders. According to Advisen, an insurance research firm, cases settled since 2005 in Europe were for average settlements of €117 million. Although some anti-corporate activists argue that the coverage creates an incentive for misbehavior, scholars find no evidence that the coverage motivates mismanagement, just as carrying auto liability insurance hardly gives drivers a reason to cause an accident. Suits against managers can come with a host of punitive effects, including reputational loss, jail time and possible fines in the event of a scandal. Enron's Skilling is serving a 24-year term in prison and was fined $45 million. Fines are typically excluded from a policy's benefits. D&O coverage tends to be best advised on by lawyers and specialized insurance brokers. The specialists recommend that policies go far beyond the basic requirements of being large enough to cover the cost of settlements. They stress that policies must be tailored for each individual buyer, depending on the area of business and the risks present. In the US, a large number of D&O claims are made for a manager's conduct related to human resources, such as hiring and firing decisions. But an increasing number of claims are being filed against directors and officers for securities-related misconduct. What's more, American law is known to have a long arm from which managers around the world might need to defend themselves. Witness the Enron-related case of the NatWest Three. The British bankers involved were extradited to and tried in the United States, where they also served prison terms for wire fraud committed in the UK.

Megan Colwell, an expert in management liability insurance at Woodruff Sawyer & Co., a California insurance brokerage and specialist of international legal actions, offers her clients a choice of roughly 10 to 15 insurers. Her firm is paid by commission from insurance companies or consulting fees from the client. Colwell recommends that companies with international operations acquire specialized advice to align their corporate D&O program to the risks in different countries.

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Transfer pricing in China

2010-11-25T02:28:00.001-08:00

Transfer pricing in China

Braxton is an international tax specialist in transfer pricing. This also covers China. Years ago, when we actively represented corporate clients in Chinese tax matters, there was not a transfer pricing "problem" for smaller wholly foreign enterprises, as the number of SAT specialists was so small that they could only delve into matters of corporate entities far larger than those I represented. But now it is quite different. On July 12 Circular 323 was issued by the SAT. The SAT is beginning a nationwide inspection of transfer pricing documentation. Local authorities have been instructed to select for audit for years 2008 and 2009 a minimum of 10 percent of taxpayers who have related-party transactions. While we don't know if this instruction filtered down to all levels of SAT offices, we do know that it has reached the Guangzhou SAT. It is time for some of those smaller businesses - the type that we used to work with - to be concerned about having their transfer pricing documentation in order. From what we hear, it will be more than the minimum of 10 percent who will be audited.

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Moving from the UK to a prescribed territory

2010-11-24T03:10:00.001-08:00

Moving from the UK to a prescribed territory

According to the Savings Directive, "If a UK individual changes address to a prescribed territory you will need to report on the basis of the new address. This may mean you need to obtain additional information and/or update your system.

For example, a UK paying agent pays savings income to an individual who lives in the UK. This is not reportable under the scheme. He has a contractual relationship made on or after 1 January 2004 with the individual.

If the payee moves to Spain, they will become reportable and the paying agent will need to update his records to fulfill his obligations under the scheme. Since he has a relationship which began on or after 1 January 2004 with the individual, he will also need to verify the name and address in addition to obtaining and verifying the TIN or the date and place of birth.

Where both the identity and UK address were verified to KYC standards, and the contractual relationship began after 1 January 2004, subsequent changes can be 'self certified' in accordance with paragraph 183.

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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."

More about International Tax

NEW ADMISSIONS IN THE PLUS MARKET (LONDON)

2010-11-19T00:32:00.001-08:00

Imperial Music and Media Plc

was floated on the PLUS quoted market on the 9th June 2010 and intends to make "investments in new musical talent within the UK music industry, predominantly in the areas of rock, jazz and easy listening". The directors "anticipated that investment will be by way of investing capital into and the management and development of new talent, or acquiring and managing the rights and revenues to existing artists catalogues and/or managing existing recorded artists."

Imperial Music and Media Plc has cash of circa £200,000 and has the largest market cap of £3.44m.

Japanese Turnaround Capital Plc was floated on the PLUS quoted market on the 9th April 2010 and intends to "take advantage of opportunities in connection with distressed financial assets in Japan, primarily in relation to portfolios of distressed Japanese consumer loans."
Japanese Turnaround Capital Plc has cash of £448,000 and net assets of £194,000.

more information on:

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Cash shells in the Plus Markets Exchange in London

2010-11-18T03:38:00.001-08:00

The PLUS Markets is a London based stock exchange aimed at small and mid-cap companies looking to raise capital and gain international exposure with a flexible regulatory environment compared to the traditional capital markets.

PLUS offers the same advantages of AIM such as the ability to raise funds, increase company profile and tax advantages for investors but with the added benefits of lower costs and a more flexible regulatory regime.

Cash shells are companies with a stock market quote, board of directors and money in the bank but no active business.

Generally set up as an „investment vehicle‟, the entrepreneurs and shareholders of a cash shell are looking for a business to fund.

Rather than going through the traditional Initial Public Offering (IPO), a company looking for capital is „acquired‟ by a cash shell, known as a „reverse takeover‟. A reverse takeover can be a quicker and more certain route to a public quotation compared to a standard IPO with the added benefit of a known quantity of available capital.

you can find more information about the Plus Markets Exchange on:

http://www.Braxton-co.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

2010-11-16T03:32:00.000-08:00

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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International tax and income tax

2003-08-10T22:15:00.000-07:00

International tax and income tax

You may find information about International tax and income tax in www.tax-international.com and in www.braxton-co.com , among other sources. Most of the sites about international taxation do not show any conexion, although, between International tax and income tax

Income Tax

List of top consulting firms 2012

Memoranda is signed in THE DUBAI FINANCIAL CENTER

One-stop-shop

Social Ties Driving Internationalization for SMEs from Azores Islands, Portugal

Growth Motives.

European Union Direct Taxes

Internationalization

OCDE prerrogatives for internationalisation on SME

An opinion from one of our readers commenting the news from Yahoo

Proposta da Comissão

Behavioral marketing by International Lawyers

Litigation Risk

Transfer pricing in China

Moving from the UK to a prescribed territory

Advantage of Cash shells in the Plus Market Exchange in London

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

NEW ADMISSIONS IN THE PLUS MARKET (LONDON)

Cash shells in the Plus Markets Exchange in London

Private Foundation in Guarnsey

Hybrid entities and reverse hybrid entities

International tax and income tax

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