The Ukraine State Fiscal Service (SFS) recently issued guidance letter 4998/IPK/99-00-05-06-02-06 regarding the tax treatment of the contribution of a non-resident's shares in an unlisted Ukraine resident company to the authorized capital of another resident company. The letter notes that Ukraine source income of a non-resident is generally subject to tax at a rate of 15%. With respect to shares in particular, the letter provides that Ukraine source income includes the sale or other alienatio…