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Sean Foley The Internal Revenue Service (IRS) has published final regulations concerning the determination of the earnings and profits attributable to the stock of controlled foreign corporations (CFCs)-or former CFCs-that are or were involved in certain non-recognition transactions (TD 9345). Under section 1248(a), a gain that is recognised upon the sale or exchange of stock in a CFC by a US shareholder (US person that owns, directly, indirectly or constructively, 10% or more of the total combined voting power of all classes of stock of the foreign corporation entitled to vote) is included in the US shareholder's gross income as a deemed dividend. This equates to the extent of the US shareholder's ratable share of the CFC's post-1962 accumulated E&P. The regulations are effective to income inclusions that occur on or after July 30 2007.

The Treasury issued a consultation document in June 2007 inviting comment on the proposed reform of the UK's controlled foreign company (CFC) regime. The paper proposes a new income-based system for controlled companies (CC).

Tracey Bentham Tracey Bentham has been appointed partner in charge of the West region tax practice at PricewaterhouseCoopers (PwC). She joined the firm in 1982 and has been a tax partner since 1999. In her new role Bentham will be responsible for a practice of more than 100 tax specialists, covering the entire spectrum of tax advice from international tax structuring to share schemes and reward.

Jamie Fowler, a Grant Thornton US tax partner, has been promoted to the firm's new national managing partner - national tax process group position. As a result of this position, she will join the firm's national leadership and national tax leadership teams.

Jim Tobin Ernst & Young has announced that Jim Tobin, the firm's global international tax services (ITS) leader, has shifted his primary base to the UK. He will continue his responsibilities as ITS leader and will also become a key member of the UK tax leadership team.

Edward Tanenbaum Two significant pieces of international tax legislation are working their way through Congress this autumn.

Sharon Shulman Motti Tagar In our previous article, we discussed the ability of Israeli technology companies to enjoy certain tax incentives in Israel. This article will discuss the Israeli tax treatment of capital gains and dividend, as another consideration in structuring an acquisition of an Israeli technology company.

By Catherine Snowdon, Americas reporter

Tax audits can be daunting and scary. When a company is facing that process in a new country for the first time, it can also be confusing. Catherine Snowdon learns about the investigations carried out in various countries and hears how best to deal with the tax authorities.

Although tax is no longer necessarily the primary driver for restructuring, companies can nevertheless optimise taxes by planning the restructuring appropriately, reveal Indraneel Roy Choudhury and Rakesh Mishra of PricewaterhouseCoopers