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The Internal Revenue Service (IRS) is at long last changing its rules governing ex parte communications.

The ECJ ruling will affect all banking transactions A judgment from the ECJ has stated that electronic messaging services for financial institutions are not covered by the VAT exemption on banking transactions.

Along with the appointment of Greg Wiebe as global head of tax – succeeding Loughlin Hickey – KPMG has also created a new role of global deputy head of tax. Ernst Gröbl, head of tax in Germany, as well as head of tax for KPMG Europe and KPMG's Europe, Middle East, Africa (EMA) region, takes the role. He will focus on major global clients and markets.

As of August 28, Erik Corwin, formerly a partner at Ropes & Gray in Washington DC, joined the IRS as Deputy Chief Counsel (Technical).

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com

Sean Foley Landon McGrew The Internal Revenue Service (IRS) and the US Treasury Department recently released final regulations addressing certain triangular reorganisations, focusing on the so-called Killer B transactions. (TD 9526). The final regulations generally adopt the rules set forth in the temporary and proposed regulations that were released in 2008. (TD 9400). While the final regulations are technically effective for transactions occurring on or after May 17 2011, the temporary regulations had been effective dating back to September 22 2006.

José Manuel Cardona The economic and financial crisis is prompting insolvency processes at some Spanish companies. These processes require detailed analysis. The natural reaction of companies is to try and solve their financial and cash problems using out of court solutions, similar to those provided in the laws of other countries, such as refinancing processes. If these processes fail, the only remaining option is a concurso insolvency proceeding, consisting of a long and costly court process that usually has steep corporate income tax consequences.

Edward Tanenbaum Tola Ozim On July 14 2011, the Internal Revenue Service (IRS) issued Notice 2011-53 detailing a new delayed phase-in of certain of the provisions of the Foreign Account Tax Compliance Act (FATCA).

Salman Shaheen speaks to David Gauke, Exchequer Secretary to the Treasury and the man behind UK tax policy, about reform, competitiveness and tax justice.

Gary Richards and Kevin Cummings of Berwin Leighton Paisner in London analyse the UK CFC consultation document and discover that it would be paradoxical if the new rules meant that one of the main reasons for introducing the worldwide debt cap – upstream loans – was caught by them.