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By Jack Grocott

By Joanna Faith

by Joanna Faith

A monthly commentary on the notable facts, figures and goings-on in the tax world, so called to give you a gentle exit from International Tax Review each month.

Angus Wilson, Lydia Simpson and Darren Mellor-Clark KPMG has boosted its UK practice with three senior appointments.

William Wilkins William Wilkins, President Obama's nominee as chief counsel of the Internal Revenue Service and an assistant general counsel in the Department of the Treasury, has been a partner in the tax group of the Wilmer Cutler Pickering Hale and Dorr law firm since 1988.

Nathan Hochman Nathan Hochman, assistant attorney general for the Tax Division of the US Department of Justice for the last year – the chief prosecutor in tax criminal cases, has joined Bingham McCutchen as a partner in its Santa Monica, California office. He will be part of the complex litigation practice, with a focus on white-collar defence and tax.

Sean Foley The Internal Revenue Service (IRS) and Treasury department recently identified a new transaction of interest in which a US taxpayer (i) interposes a US partnership between higher-tier controlled foreign corporations (CFCs) and a lower-tier CFC and (ii) takes the position that subpart F income generated by the lower-tier CFC is not included in the US taxpayer's income under section 951(a). IRS notice 2009-7 explains that the IRS and Treasury department are concerned that this transaction has the potential for tax avoidance or evasion, but lack sufficient information to determine if designation as a tax avoidance transaction is appropriate. Consequently, the IRS and Treasury department have identified this transaction, along with substantially similar transactions, as transactions of interest.

Edward Tanenbaum On March 2 2009, Senator Carl Levin (D-MI) introduced the Stop Tax Haven Abuse Act, S 506. The stated goal of the bill is to combat tax evasion through tax havens, money laundering and the use of tax shelters.

In a long awaited and welcome move, Finance Bill 2009 published on May 7 provides for a new regime of tax relief for intangible assets.