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Jack Cummings Edward Tanenbaum IRS Notice 2007-57 adds a new category of listed transaction that involves loss importation. The technique involves the most elementary of planning techniques: the domestic taxpayer arranges to reflect on its US income tax return the loss leg of a hedge entered into by a foreign entity. In order to avoid also reporting on its US return the gain leg of the hedge, the taxpayer insures that the foreign entity is a corporation for US tax purposes when it recognises the gain. Finally, to close the loop, it is necessary for the US taxpayer not to own the foreign entity long enough as a corporation to have to report its income under subpart F.

There has been a long-running dispute on the dedutibility of hedging cost against premium derived from warrant issuances for Taiwan tax purposes. Previously, 25% income tax was levied on the warrant premium after accounting for origination costs rather than on the gains from the issuance of warrants. The rationale behind the foregoing tax treatment was based on the concept that capital gains from the trading of securities are tax-exempt whereas capital losses may not be tax-deductible.

The tax authorities need more rules to help them implement international transfer pricing standards, believe Rubén Hernández and Gabriela Villavicencio

Rosa María Gil and Diego González-Béndiksen explain how transfer pricing rules have developed in Ecuador since they were introduced more than two years ago

Sergio Illanes, Miguel Zamora and Ana Paula Güitrón summarise the key points of the Chilean transfer pricing regime

The countries of Central America will probably incorporate transfer pricing rules in to their laws in the near future, report Emilio Angeles and Alejandro Cervantes

Joan O'Connor has been selected as the new president of the Irish Taxation Institute (ITI). An international tax partner with Deloitte, she has 25 years' experience in the taxation profession, advising Irish domestic public and private companies and inbound multinational companies.

Paul Chambers S. Nonnenkamp The law of June 8 2007 extends the application of the aid to the audiovisual sector to 2015 and slightly amends the scope:

Claudia González-Béndiksen and Paola Gutiérrez expect the tax authorities in Peru to increase their focus on transfer pricing issues soon

Peter Dachs It is proposed that from some time next year secondary tax on companies will be changed to a tax on the shareholder receiving the dividend (as opposed to its current form where it is imposed on the company declaring the dividend) and levied at a rate of 10%.