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The accounting firm has found a successor to Danny Beeton as UK head of transfer pricing. Wendy Nicholls is joining immediately as a partner and head of transfer pricing. She was formerly with PricewaterhouseCoopers.

Heather Maloy has been appointed commissioner of the Large and Mid-Size Business division of the Internal Revenue Service in the US. She joins from law firm Skadden Arps Slate Meagher & Flom.

Edward Tanenbaum On August 19 2009, the Internal Revenue Service (IRS) and the Justice Department announced that they had reached an agreement with international bank UBS regarding the IRS' John Doe summons to obtain approximately 4,450 names of US taxpayers with accounts in UBS. The Justice Department had filed a petition in February 2009 seeking enforcement of the John Doe summons served on UBS in July 2008 that had asked for the names of as many as 52,000 US taxpayers with undeclared accounts at the bank. The principal terms of the settlement agreement are as follows:

Vladimir Kotenko The state tax administration (STAU) has opined that the salary received by a foreigner from a Ukrainian payroll is taxed at 15% only if such an individual has opted for Ukrainian tax residence status. In all other cases, Ukrainian-sourced income of non-residents (except for interest, dividends and royalty) should be taxed at 30%.

David Cuéllar José González An amending protocol to the August 3 1993 income tax treaty between Mexico and Switzerland was signed on September 18 2009.

Akio Takisaki On August 30, the Democratic Party of Japan (the opposition party) won a big election victory in the House of Representatives, the lower house of the Diet.

Nicolas Jacquot French business tax (taxe professionelle), which was created in 1976, is one of the four direct taxes collected by local councils. Any individual or legal entity engaged on a habitual basis in a no-salaried or professional activity is liable to this local tax, the rate of which is decided by local councils each year. The tax has two bases: the rental value of property, and equipment and movable assets, used for the needs of the business activity.

Hartwig Welbers A key condition of Organschaft or tax group is a valid profit pooling agreement between parent and subsidiary. Its effect is that the subsidiary surrenders its entire annual profit to the parent while the parent enters into a corresponding obligation to assume any loss. Company law requires compensation of minority shareholders for their inability to receive a dividend on the surrender of the entire annual profit to the parent.

Paul Tamaki Sabrina Wong The Tax Court of Canada has held that, where a statutory rule does not apply, the residence of trusts should be determined using the test of central management and control (CMAC).

The ratification of the Vienna Convention is an important step in bringing to Brazil the international standards of interpretation of treaties in general and, specifically, of tax treaties, explain Luiz Felipe Ferraz and Julia Nogueira of Demarest e Almeida