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  • The changes to its exemption regime for foreign-sourced income has boosted Singapore's credentials as a pro-business, tax-competitive jurisdiction, explains Sunil Agarwal and Kah Chuan Ho of PricewaterhouseCoopers
  • By Catherine Snowdon, Washington DC
  • Lewis Steinberg has left UBS to join Linklaters as co-head of the US practice and head of US tax.
  • US law firm DLA Piper has expanded its international tax practice with the appointment of three transfer pricing specialists: two principal economists and one of counsel. Clarke Norton has 17 years transfer pricing experience and was formerly chief economist of the Inland Revenue Service's Advance Pricing Agreement Program.
  • Edward Tanenbaum The Internal Revenue Service (IRS) issued temporary regulations on the application of section 367 of the Internal Revenue code in cross-border stock transfers governed by code section 304. The temporary regulations are intended to stop a transaction used by some taxpayers to repatriate cash to the US tax-free.
  • Sean Shimamoto Sean Shimamoto and Steven Matays have become partners of Skadden, Arps, Slate, Meagher & Flom's tax practice. Shimamoto, in the firm's Washington DC, office, represents major corporations and private equity funds on US federal income tax matters, including M&A, debt and equity offerings and joint ventures. His practice also covers tax matters in the energy sector. He also advises clients on tax matters in the energy sector, particularly involving renewable energy projects.
  • Patrick Sinewe, who specialises in restructuring and group tax law as well as on M&A, leveraged buy-out and private equity related tax issues has become a partner of Bird & Bird in Frankfurt.
  • Kevin Dolan has left Merrill Lynch, where he was a senior vice-president and senior tax counsel, to join Shearman & Sterling as of counsel. Before his nine years at the bank, Dolan was head of Weil Gotshal & Manges' Washington tax practice and also worked in governmenet for the Internal Revenue Service, the Treasury and the SEC.
  • Sean Foley The IRS rece-ntly posted interim guidance on its website clarifying the meaning of the term commen-cement date for purposes of the mandatory arbitration process in mutual agreement procedure (MAP) cases under the US-Belgium income tax treaty. The interim guidance was generally welcomed by taxpayers because, pending publication of more formal procedures, the interim guidance could prevent unnecessary delays in resolving MAP cases under consideration by the US and Belgium competent authorities.
  • Rafael Calvo Traditionally, neither the Spanish tax authorities nor the law courts have been particularly receptive to the arguments of taxpayers claiming that the application of tax laws should be consistent with the principles and requirements of EU law. However, the trend has been the opposite lately.