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Robert Mirsky Ernst & Young has announced that Robert Mirsky has joined its 350-people strong hedge funds advisory practice. He has been appointed as a tax partner in the UK.

Boston's Sullivan & Worcester has recruited a well known international tax practitioner as a partner.

President Bush has nominated Nathan Hochman as head of the tax division at the US Department of Justice.

Marathon Oil has promoted Stephen Landry to global head of tax. He succeeds veteran tax director James Meara.

David Forst and Barton Bassett of Fenwick & West discuss new income tax rules and a treaty that will affect international deals

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.

Franchising may be an appropriate framework for analysing intra-group transactions, including potentially in industries where third-party franchising is generally not observed, believe Emmanuel Llinares of NERA Economic Consulting in Paris and Nihan Mert-Beydilli of NERA Economic Consulting in Chicago

The European Commission has amended the transitional measures it applied to Belgian coordination centres before the European Court of Justice (ECJ) ruled against those measures in 2006. The Commission has taken almost 18 months to make the changes.