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Business restructuring was an important issue for tax executives even before the economic downturn. In advising management on company reorganisations within and between countries, they sought to ensure units were achieving tax efficiency.

A monthly commentary on the notable facts, figures and goings-on in the tax world, so called to give you a gentle exit from International Tax Review each month

US law firm Winston & Strawn has promoted tax lawyers David Colin and Karen Kowalski to partner. Colin has experience with optimisation of indirect taxes in cross-border transactions, VAT advisory matters, negotiation with tax authorities, and due diligence counselling.

Caplin & Drysdale has established a practice dedicated solely to providing legal services to help resolve tax matters using alternative dispute resolution (ADR). The practice, called ADRTax, will provide alternatives to the firm's clients and help them bridge differences with federal, state and foreign tax authorities.

Michael Velten Transfer Pricing Associates (TPA) has appointed Michael Velten to its Asia team. Velten will lead the firm's global financial services practice and will be based in Hong Kong.

A former international tax official in the US Treasury has joined Deloitte. Gretchen Sierra, who was an attorney-adviser in the Office of the International Tax Counsel in the Office of Tax Policy, has started work in the firm's international tax group in Washington, DC.

Sean Foley Alexey Manasuev On the final day of 2008, the US Treasury department and the IRS issued temporary regulations addressing cost sharing arrangements (CSAs) between controlled taxpayers.

An income tax amendment regarding an extension of the loss carryforward period passed the 3rd hearing in the Legislative Yuan on January 6 2009. The carryforward period has now been extended from five to ten years.

Álvaro de la Cueva Unlike most of its OECD counterparts, Spain has traditionally considered that most payments for software fall under the category of royalties. As such, Spain inserted an observation in paragraphs 14, 15, 17.1 and 17.4 of the commentaries on article 12 of the OECD Model Tax Convention reserving its right to charge tax in cases where less than full rights were transferred and the payments were for the commercial exploitation of the software, or for the business use of not-absolutely-standardised software.

Henry An David Jin-Young Lee On September 1 2008, the ministry of strategy and finance announced various proposed amendments to tax laws which include provisions to provide penalty relief to taxpayers maintaining contemporaneous transfer pricing documentation.