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True Partners Consulting, which recently inaugurated an international network of tax consulting firms, has hired three new managing directors in the US.

Ken Okawara Ken Okawara has joined the Tokyo office of Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) as head of transfer pricing and economic analysis.

Edward Tanenbaum The Internal Revenue Service (IRS) continues its scrutiny of the favourable tax treatment afforded to hedge funds and private equity firms. In recent months, Congress has responded to the IRS's concern that hedge funds and private equity firms – and their managers – are paying tax at lower rates than corporations and most individuals. First, House Democrats introduced bills that would impose corporate-level tax on publicly traded partnerships (PTPs) that derive income from investment adviser or asset management services; under current law, certain PTPs with predominantly passive-type income are taxed only once, at the partner level. Congress is also concerned that the managers of hedge funds and private equity firms are able to receive their compensation through partnership carried interests, thereby paying tax at the capital gains rate of 15%, rather than the maximum ordinary rate of 35%.

By Catherine Snowdon, Americas correspondent

German banks should put their strategy into place now if they want to be ready for the flat tax. Hans-Ulrich Lauermann and Benjamin Laves of PricewaterhouseCoopers explain why

In 2007 Germany reformed its tax system to make itself more attractive to foreign investors. Stefan Ditsch, of PricewaterhouseCoopers, explains

Rebel Curd, Robin Hart, and Catie Magelssen of the Ballentine Barbera Group, a CRA International company, explore the potential for risk in an investment model recently published by the IRS

Jorge Mesta and Hernan Katz praise the economic revival in the region in recent years, but warn that countries must prepare themselves properly for the risks and challenges ahead

If applied based on sound economic principles, contribution analyses are powerful tools to address the bulk of most complex transfer pricing issues, explain Sébastien Gonnet & Pim Fris of NERA Economic Consulting

Multinational companies have identified Latin America as one of the up-and-coming areas of the global economy. More and more investment is coming into the region in all sectors, for example, financial services and energy. There are regional economic agreements such as Mercosur and the Andean Pact, but tax rules are not uniform in the region and taxpayers have to deal with different laws in each country.