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BMR Advisers has expanded its presence in India by combining with K Ravi, a tax advisory and controversy firm in Chennai. The announcement from the firm said the K Ravi employees joining BMR will further enhance its capabilities in the area of direct and indirect tax advisory and assist in augmenting its tax controversy practice at a national level.

Edward Tanenbaum Diana Wessells Treasury and the IRS have issued temporary regulations under section 901 that are intended to preclude foreign tax credit generator transactions. The temporary regulations, which are effective as of July 16 2008, modify proposed regulations that Treasury and the IRS issued in March 2007.

Henry An The Korean National Tax Service recently published its 2007 APA annual report, Henry An of Samil PricewaterhouseCoopers describes some of the key elements of the report

In economic downturns company bosses search for as many ways as possible to cut costs and bring in cash. Joanna Faith discovers the real value of the tax function in uncertain times.

Roberto del Toro On September 8 2008, the federal government presented its budget proposal for 2009 to the Mexican congress. Given that the 2008 budget included important modifications to the tax law, such as the inclusion of the single rate business tax (flat tax), the executive's approach this year was to omit important tax reforms and allow the government to further study the effect of last year's reforms.

The supreme tax court has held that continual use of the facilities provided by the customer for the fulfilment of a long-term service contract does not itself constitute a permanent establishment for the service provider - even if the arrangements go on for years. The case was brought by a Dutch cleaning company engaged as subcontractor on aircraft cleaning on a NATO airbase in Germany.

John Leopardi Jean Gagnon In view of the Canadian election called for October 14 2008, parliament was dissolved on September 7 2008, thereby ending all pending tax bills. Normally, the elected government re-introduces previous tax bills when the parliament is back in session. In 2007, amendments to the income tax act (act) were enacted under bill C-28, which included previously announced proposals regarding functional currency tax reporting and foreign affiliate rules. On June 27 2008, the Department of Finance proposed related changes to the act to assist internationally-engaged Canadian businesses in complying with Canadian tax law (proposals).

Eduardo Goldszal and Catarina Breia of KPMG in Portugal explain the country's new regulations concerning APAs.

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

Christopher Ocasal US Law firm Sutherland has strengthened its tax practice by hiring Christopher Ocasal as a partner in its Washington D.C. office.