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Fenwick & West has announced that it has elected six associates to join the partnership, from January 1. Andrew Kim is a member of Fenwick's tax group. He represents a wide variety of public and private companies in international and domestic tax matters, including both tax planning and tax controversy.

Michel Aujean Michel Aujean's new role will be to work with French companies on how they should respond to proposals to harmonise corporate tax rules throughout the EU, which are due in September this year.

Sean Foley The IRS Large and Midsize Business Division (LMSB) has issued an industry directive (LMSB-04-0907-063) on Internal Revenue Code (IRC) section 965 foreign earnings repatriation.

Edward Tanenbaum On November 28, the Treasury department office of tax policy released its long-awaited "Report to the Congress on Earnings Stripping, Transfer Pricing and US Income Tax Treaties" (report). The report contains the results of the Treasury department's analysis of three studies on earnings stripping, transfer pricing and income tax treaties and provides recommendations on how the government can reduce abuse of US tax laws and treaties and improve their effectiveness in preventing income shifting that erodes the US tax base. The report portends additional enforcement efforts and coincided with a proposal for some new information gathering on international transactions.

Dieter Endres Up to 2006, a finance ministry decree permitted tax offices to issue binding rulings, although the practice was not widespread. Recently, statutory authority for binding rulings has been enacted into the section of the Tax Management Act dealing with the tax office's duty to inform taxpayers of their rights and obligations.

Neil Wilson Tax advisers have recently been involved in discussions with the Australian Tax Office (ATO) in relation to the Australian corporate income tax treatment of Dutch co-operative entities (Dutch co-ops).

Jose Maria Cusi of Clifford Chance warns that new rules have made Spain's transfer pricing regime much tougher following significant amendments to corporate income tax

Bob Reynolds argues that tax intermediaries report could face implementation difficulties after calling for greater co-operation between advisers, authorise and taxpayers

Clemens Hasenauer Johannes Prinz Recent legislation entering into force in 2008 (Abgab-ensicherungsgesetz 2007, Mittel-standsfinanzie-rungsgesellschaften-Gesetz 2007) has introduced several changes in Austrian (corporate) income tax law.

Yuri Delikatny has left KPMG in the Ukraine to lead the tax department at law firm Norr Stiefenhofer Lutz which opened its Kiev office in December.