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Jim Ryan Jim Ryan, a partner at Ernst & Young, has become the new president of the Irish Taxation Institute. Ryan leads the human capital practice at the big-four firm. He takes over as ITI president from Joan O'Connor of Deloitte.

International law firm Clifford Chance has hired Marc Scheunemann as a partner in its Dusseldorf office. Scheunemann focuses on the tax structuring of acquisitions and investments in participations as well as inbound or outbound investment. He also has experience in the tax optimisation of company restructurings and tax issues related to corporate finance.

The merger of Czech firm Procházka Randl Kubr and its Hungarian counterpart Bellák & Partners to form PRK will include a tax practice of 30 professionals.

International law firm Paul, Hastings, Janofsky & Walker has poached Robert Culbertson, Michael Caballero and Kurt Baca from King & Spalding. They have joined the firm's global tax practice in the Washington DC office.

Edward Tanenbaum Diana Wessells On June 17 2008, President Bush signed into law the Heroes Earnings Assistance and Relief Tax Act of 2008 (the HEART act). The HEART act contains a new expatriation tax regime that applies to individuals who expatriate from the US on or after June 17 2008. As explained by the senate finance committee, Congress intends for the new expatriation rules to tighten the rules so that certain high net worth individuals cannot renounce their US citizenship or terminate their long-term US residency in order to avoid US taxes. Congress expects that the new expatriation rules will raise $411 million over the next 10 years.

Carl Pihlgren Sara Bolmstrand On June 23 2008 the Swedish tax agency submitted a proposal to the Swedish government with suggestions for limiting interest deductions on intercompany loans. The proposal was submitted to relevant parties for comment and on August 25 2008 the Swedish Ministry of Finance presented a revised proposal taking into consideration comments received.

Peter Dachs South African individuals and companies are restricted in respect of their ability to invest outside South Africa due to South Africa's exchange control rules. However, one of the ways in which individuals may make offshore investments is by means of an offshore share incentive scheme.

Daniel Armesto On September 11 2008 the European Court of Justice (ECJ) published its judgment (cases C-428/06 et al) in the preliminary ruling sought by the High Court of Justice of the Basque Country in order to determine whether the Basque Country passes the institutional, procedural and economic autonomy tests set by the European Court of Justice in the Azores case (case C-88/03) for an asymmetrical autonomous tax system not to conflict with EC state aid rules, providing further clarification as to the content and scope of the requirements of procedural and economic autonomy.

Svetlana Stroykova Ilarion Lemetyuynen Structuring investments into Russia involves transactions with shares in Russian joint-stock companies (JSCs) and limited liability companies (LLCs). If double tax treaty protection is not available, transfer of such shares may be a taxable event in Russia and related transfer pricing (TP) issues should be addressed. In 2008 a number of arbitration court cases appeared where the Russian tax authorities tried to apply Russian TP rules to transactions with shares in JSCs/ LLCs. These court cases are considered below:

Thomas Pippos The New Zealand government has recently released the long awaited document designed to kick start consideration of New Zealand's imputation regime. The document titled "Streaming and refundability of imputation credits" has received mixed reviews from many commentators.