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  • 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%.
  • 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 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.
  • Ellie Patsalos Deloitte has made a series of key tax appointments worldwide. The firm has recruited new partners in China, the UK and Switzerland.
  • Paul Farmer has joined the London office of Dorsey & Whitney. He was head of analysis and coordination of tax policies at the European Commission.
  • Jeon Goon-pyo Jeon Goon-pyo, the head of Korea's tax administration, has been arrested on charges of bribery. If he is convicted, he could spend up to seven years in prison.
  • Bela Jansen The Frankfurt office of Dewey & LeBoeuf has poached tax practitioner Bela Jansen from Clifford Chance in the city. He begins work at his new firm as a partner from January 1. This brings the tax practice in Frankfurt to a total of 16 lawyers and tax advisers, including five partners.
  • Sean Foley On October 31 2007, the Senate Foreign Relations Committee approved the new protocols to the US-Germany, US Denmark, and US-Finland income tax treaties as well as a new US-Belgium income tax treaty.
  • Irina Pushkina Nina Budazhapova One of the hot topics in Russia is the unclear application of clarifications issued by Russian authorities in favour of taxpayers, in other words, whether the tax authorities are obliged to follow such clarifications or not. According to the international practice, obtaining a binding ruling is always beneficial for the taxpayer since it provides clarity and should generally remove the risk that the tax authorities will try to charge the taxpayer with additional taxes and impose fines and penalties for related underpayment of taxes. Russian legislators are making efforts to approach the international clarifications practice. However, the position of taxpayers who obtain clarifications issued by the Russian authorised bodies is still unstable.