Cover Story Features Comment News People and Firms Tax relief Australia Belgium Brazil Canada Chile Cyprus European Union Finland France Germany Mauritius Mexico Norway Poland South Africa South Korea Spain Turkey Ukraine US Inbound US Outbound Foreign Account Tax Compliance Act: A critical analysis Bearer bonds The Netherlands Budget and the patent box Asia 2009 Europe 2009 Americas 2009		JUNE 2005 Cover Story Tax executives face new boss in Europe Sed Crest discovers who rules the tax roost in Europe and how tax directors are reacting Features Guidance offers clearer picture on repatriation The second round of repatriation guidance from the IRS helps multinational taxpayers to work-out how they should apply the section 965 incentive in the American Jobs Creation Act, according to Ernst & Young Opinion prompts more questions The Advocate General's opinion in Marks & Spencer may have provided taxpayers with ammunition to attack member states' tax consolidation rules. However, the overall position is far from clear, argues Mark Persoff of Clifford Chance Structuring UK securitizations Recent experience shows that now is the correct time to put the taxation position of UK securitization companies beyond doubt, while addressing the concerns of the industry that the UK market should remain competitive, argues Martin Shah of Simmons & Simmons How the new EU has dealt with the tax challenges The tax environment has changed in the countries that joined the EU in 2004. Corporate taxpayers may be at risk as a result, explain Philippe Norré, Ildikó Molnár and Duncan Stocks of KPMG Nordic countries attempt to lose tax image The countries in the Nordic region are changing their tax systems to make them more attractive as holding locations, explains John Larsson of Vinge How Argentina deals with tax avoidance Argentine corporate regulatory and tax anti-avoidance rules work together to fight tax avoidance by Argentine taxpayers conducting activity through tax haven companies, point out Guillermo Teijeiro and Ana Lucía Ferreyra of Negri & Teijeiro News •  Netherlands overhauls corporate tax •  UK government promises a competitive tax system •  HMRC claims avoidance rules are working •  Treasury and IRS revise rules for US tax advisers •  Who's worked on the biggest deals People and Firms •  Ballentine Barbera hires KPMG European transfer pricing head •  Herbalife hires new tax vice president •  Fried Frank lures Jones Day tax head for European launch •  Investment bank raids EY to boost transfer pricing arm •  Coudert Brothers loses global tax head to Winston & Strawn •  Ernst & Young hires Deloitte transfer pricing head •  ABA appoints new chair of corporate tax committee •  DLA Piper hires new head of tax for Asia In brief •  Argentina gives tax breaks to energy companies •  Australian Budget is good news for foreign investors •  US tax authorities issue more repatriation guidance International Updates •  Argentina - New bill tries to reinforce anti-evasion rules •  Australia - Key points from the 2005 Budget •  Belgium - New ruling practice on the right track •  Brazil - Taxpayer council releases new transfer pricing decisions •  European Union - When international tax clashes with EU law •  Germany - What the new tax relief package would mean •  Ireland - What Marks & Spencer means for Irish taxpayers •  Italy - How the Savings Directive works in Italy •  Japan - Capital gains tax on dispositions of real estate holding interests by non-residents •  Luxembourg - Tax treaty network expands and holding company window to close •  Mexico - Lower customs duties under new agreement with Japan •  Netherlands - Implications of the corporate tax white paper •  Poland - Strict new rules on input VAT deductions for cars •  Russia - Double tax treaties, foreign partnerships and beneficial ownership •  South Africa - New tax reporting rules take effect •  Spain - Goodwill and corporation tax •  UK - What the Advocate General's opinion in Halifax means •  US Inbound - Changes to Japanese law raise check-the-box issues •  US Outbound - Treasury issues second round of guidance for dividend repatriation Directory •  Cerha Hempel Spiegelfeld Hlawati •  Deloitte •  Dewey Ballantine •  Ernst & Young •  Garrigues •  LECG •  P+P Pöllath + Partners •  PricewaterhouseCoopers •  SchneideR'S •  Simmons & Simmons •  Uría & Menéndez Special Features •  Expatriate Tax

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