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Russian legislation has not kept up with the rapidly changing situation in the derivatives market. Substantial amendments to tax and civil legislation regulating derivatives transactions are long overdue, believe Alexei Kuznetsov and Ivan Sychev of Ernst & Young

By Joanna Faith

The full effects of a new flat rate business tax on taxpayers have yet to be seen, believe Karol Campo, Santiago Chacon and Terri Grosselin of Ernst & Young

International mining companies have stopped work on new investment projects after the Zambian government imposed a set of new company taxes. In a time of rising copper prices, the administration wants to secure more revenue for itself and so has raised the tax charges on mining concerns.

Michael Desmond is rejoining McKee Nelson in Washington DC as chairman of the firm's tax practice. He left the firm three years ago to become tax legislative counsel in the US Treasury Department.

Paul Williams Jane Dodd On April 23 the European Court of Justice (ECJ) gave its judgement in the CFC and Dividend Group Litigation v Commissioners of the Inland Revenue (C-201/05). This process was concluded by what is termed as a reasoned order. This means that instead of following the normal procedure and awaiting a hearing and advocate-general's Opinion, the court moved straight to a judgement. It answered the questions posed by the UK's High Court by reference to reasoning from other recent ECJ judgements. Here, one of the judgements used was that of the Cadbury Schweppes (C-196/04) case which looked at the validity of the UK's controlled foreign company (CFC) rules.

Sean Foley The IRS has issued final and temporary regulations (T.D. 9400) under section 367(b) providing guidance on certain triangular reorganizations (commonly referred to as "Killer B" transactions) involving one or more foreign corporations. The IRS and Treasury believe that these transactions raise policy concerns because they can allow the effective repatriation of a subsidiary's earnings without the imposition of US tax. The regulations generally apply to transactions occurring on or after May 23 2008 (however, see the discussion below).

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition £3.6 billion ($7.2 billion) Babcock & Brown-led consortium Angel Trains Freshfields Bruckhaus Deringer, David Taylor & Peter Clements Acquisition $5.9 billion Verizon Wireless Alltel Debevoise & Plimpton, Peter Furci & David Lutz Wachtell, Lipton, Rosen & Katz, T. Eiko Stange

Ireland has become a jurisdiction of choice for making equity investments in China and Japan, say David Lawless and Sean Murray of Dillon Eustace

Although the UK's transfer pricing requirements are onerous, HMRC is attempting to make things easier for companies. Shiv Mahalingham of Alvarez & Marsal Taxand UK explains why hope is in sight