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  • Victoria Judson has joined the IRS as division counsel and associate chief counsel (tax exempt and government entities).
  • Evgeny Timofeev Anna Zelenskaya After almost 10 years of debate the President finally signed the reformed transfer pricing regulations into law on July 18 2011. The new regulations will be effective starting 2012, subject to certain transitional period when higher thresholds would apply for a transaction to qualify as controlled and requiring documentation, as well as reduced or no penalties for transfer pricing violations.
  • Tiago Cassiano Neves In the context of the Portuguese bailout, Portugal signed a Memorandum of Understanding (MoU) with the IMF/EU/ECB, where it agrees to adopt several legislative structural measures aimed at creating an economic environment that allows for economic growth and stability and control of public expenditure over the next three years. The MoU also includes noteworthy policy tax measures, which are likely to be included in the 2012 budget proposal.
  • As the UN’s star in global transfer pricing rises, officials, taxpayers and practitioners are discussing the role it plays in shaping policy and how that affects the OECD. Sophie Ashley explores the multiple dimensions of international transfer pricing guidance.
  • 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.