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Roberto del Toro David Cuellar The Mexican tax authorities published on December 31 2007 a new set of miscellaneous tax regulations including, among others, numerous clarifications on several items (such as definitions, calculations and procedures) related to the recently enacted flat tax.

Akio Takisaki On June 28 2007, the Tokyo high court ruled against the Japanese national tax agency's appeal to re-characterise a Tokumei Kumiai (TK) as a Nin-i Kumiai (NK) and treat the TK investor as having a permanent establishment in Japan. The decision is remarkable because it supports the taxpayer who established a tax-savings driven structure.

The financial and economic turmoil of the last six months in the US is beginning to influence the campaigns of presidential hopefuls. As International Tax Review's Americas correspondent Catherine Snowdon discovers, despite advice from some of the best economic brains in the US, there are no obvious answers on tax

Marco Da Re and Davide Bergami of Ernst & Young in Italy argue that Italy's independent line on permanent establishment could be a source of future problems for business

Nélio Weiss Philippe Jeffrey The Brazilian senate rejected on December 13 2007, the proposal to extend up to December 2011 the application of the temporary contribution on financial activities (CPMF), which consequently expired on December 31 2007.

Lynch Jiang of Deloitte argues that China's export VAT system is too complicated and needs further reform

At a time when tax competition between states is growing and its own members toughen their regimes against international tax evasion, the Organisation for Economic Cooperation and Development (OECD) is encountering new pressures. Bob Reynolds asks Jeffrey Owens, director of its centre for tax policy and administration, how it can remain effective

The Internal Revenue Service has identified four necessary components of an intermediary transaction tax shelter (ITTS). An ITTS is a loophole which attempts to avoid corporate income tax from the sale of assets. The components are: a target corporation directly or indirectly owns assets and has insufficient tax benefits to eliminate or offset tax in whole or in part; at least 50% of the target corporation's stock is disposed of by its shareholders, other than in a liquidation transaction within a 12 month period; within the 12 months before or after the shareholders disposes of at least 50% of the target corporation's stock, its assets are sold to one or more buyers; and the target corporation's built-in tax is purportedly offset, avoided or not paid.

The US Treasury has outlined three approaches to reforming the US business tax system in a new report on the corporate tax system and global competitiveness.

Many companies operating in Ecuador face the prospect of transfer pricing adjustments after the country's national assembly voted through a package of tougher measures. The new law will oblige multinational companies to extend the information given in transfer pricing reports.