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Akio Takisaki Recently the Tokyo High Court ruled that a US LLC (limited liability company) shall be treated as a foreign corporation for Japanese tax purposes and that its distribution to a Japanese taxpayer shall be taxed as dividend income in Japan.

Top-down and bottom-up represent the two types of valuation logic that exist for the quantification of arm's-length royalties for know-how and knowledge in intercompany transactions, explain Alexander Vögele and Wolf Witt of NERA Economic Consulting

Welcome to International Tax Review's guide to intellectual property for 2007. Tax practice is developing all the time. The main influence for this is the increasing sophistication of officials at tax authorities around the world. As they build on their knowledge about different strategies and techniques, they are pressing taxpayers to come up with more and more evidence about their transactions, and more and more justification for the approaches used. When the planning and structuring concerns intellectual property, this pressure can be intense.

After a slow start, the pace of treaty negotiations has picked up, report Carlos Iannucci of Deloitte in Argentina, Cristina Arantes Berry of Deloitte in Brazil and Anthony Cook of Deloitte in Chile

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

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.

The Isle of Man has adopted a zero-10 tax regime. Jersey and Guernsey are about to do so. KPMG's Tony Mancini in Guernsey, John Riva in Jersey and Greg Jones in the Isle of Man compare the three systems

Laurent Borey, who heads the Paris tax team of the Mayer Brown, has been appointed to the worldwide tax board of the firm. He is the only European on the board whose other five members are American.

Paul Farmer has joined the London office of Dorsey & Whitney. He was head of analysis and coordination of tax policies at the European Commission.