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By Ralph Cunningham

By David Stevenson

Tax avoidance is in the news. And taxpayers have not been responding to it. The issue has been a key issue for taxpayers and officials for sometime. They have argued for years about what it is and it is not. The authorities have introduced disclosure rules so they get information earlier about which structures and planning they should examine more closely.

Michael Shikuma has become a partner of White & Case in Tokyo. He is a certified public accountant and Gaikokuho Jimu Bengoshi (registered foreign lawyer), as well as a member of the Hawaii State Bar. He advises clients on the taxation of cross-border transactions and restructurings, and high-net-worth individuals on personal and international estate planning in the US, Japan and the Asia-Pacific region.

Twenty partners will make up the tax practice of a new Italian law firm following the merger of Camozzi & Bonissoni Varrenti & Associati and Studio Associato LCA.

John Whiting John Whiting has been appointed to the new role of tax policy director at the Chartered Institute of Taxation (CIOT ) in London. The practitioner will take early retirement in June from the London office of PricewaterhouseCoopers, where he is a partner. Whiting's brief is to lead the development and presentation of the CIOT's views on tax policy matters, making sure these are developed consistently within all the CIOT's technical work.

John Belsey John Belsey has moved to Dubai to head Deloitte's international tax services and M&A tax practice in the Middle East. He was formerly an M&A tax partner in London and was the client relationship partner for some of the firm's biggest global clients, as well as leader of the firm's services to the UK government and public sector.

Phani Tillirou Cyprus is established as an international business and financial centre and has the lowest corporation tax rate in the EU of 10%. A significant number of double tax treaties have been concluded, the usage of which, has greatly prevented double taxation resulting in a reduction of the tax payable. The existence of such treaties combined with the low corporate income tax in Cyprus offer tremendous possibilities for tax planning through Cyprus.

Sean Foley On Christmas Eve, in the closing days of the Bush administration, the US Treasury department and the IRS released final and temporary regulations addressing the treatment of contract manufacturing arrangements under the US anti-deferral regime known as Subpart F. The final and temporary regulations are effective for tax years of controlled foreign corporations (CFCs) beginning after June 30 2009.

Edward Tanenbaum The qualified intermediary (QI) system is a set of rules governing the "know your customer" information gathering process, as well as withholding and reporting obligations with respect to payments made by US withholding agents to foreign financial institutions holding custodial accounts on behalf of their beneficial owner customers. As a general rule, in exchange for not disclosing the identity of foreign beneficial owners to the withholding agents or to the IRS, an elaborate systems and procedures check is required to be performed by the foreign financial institution's external auditor who is then required to furnish a report to the IRS with its findings.