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Peter Dachs South Africa's recent Budget contained a number of surprising and far reaching amendments.

Rajendra Nayak Ganesh Pai The Mumbai Income Tax Appellate Tribunal (ITAT) in the case of Van Oord Dredging & Marine Contractors BV vs. DDIT (Mumbai) 105 ITD 97 examined the taxability under the India-Netherlands tax treaty (the treaty), of an arbitration award. The tax payer was an international dredging contractor and a tax resident of the Netherlands. It executed contracts in India through project/site offices maintained in India. Subsequent to closure of its project/site offices in India, the taxpayer earned income pursuant to an arbitration award, in relation to a project that was completed in an earlier year. The issue before the ITAT was the taxability of such income considering that there was no permanent establishment (PE) of the taxpayer in the year of receipt of income.

Stephen Nelson Now that the new PRC Enterprise Income Tax Law has passed and will enter into effect next year, foreign investors should consider whether it is appropriate to restructure their investments in China to cope with the changes.

Among the initiatives of the Chilean government to foster investment contained in the Chile Invests project, the executive sent a bill to Congress with a special regime for accelerated depreciation. The project bill applies to those taxpayers subject to corporate tax (First Category Tax) and sets forth that if between March 1 2007 and December 31 2008 the taxpayer acquires new assets locally or import assets into the country, they will be able to deduct a depreciation quota equivalent to 50% of their net value in the year in which they start using them. The balance of 50% will be subject to the existing depreciation rules. In regard to this portion, taxpayers will have to opt between the linear and the ordinary accelerated depreciation regimes.

Doug Richardson Kurtis Bond The 2007 Canadian federal budget (the Budget) was released by the minority Canadian Conservative government on March 19 2007 and was passed in the House of Commons on March 27 2007.

Nélio Weiss Philippe Jeffrey According to recently issued central bank regulations (circular no. 3345, dated March 16 2007), individuals and legal entities resident, domiciled or with headquarters in Brazil, are required to report annually to the Brazilian central bank (BACEN) their assets in foreign currency and any asset and/or right maintained abroad. The information must be disclosed to the BACEN through a declaration (forms are available in the bank's website: www.bcb.gov.br).

Edward Tanenbaum The Advice Memorandum 2007-006 is generic legal advice from chief counsel to the IRS field, assuring the field that a domestic corporate purchaser of a foreign target eligible entity (treated as a default corporation) can make a section 338(g) election and step up the basis of the target's assets, despite the fact that no US tax will be paid, and whether or not the election is extended to a US subsidiary of the target. The target was irrelevant for US tax purposes prior to the purchase, meaning generally that it had no US owners or business.

Oleh Marchenko Although the political situation may slow down the process, the Ukraine's State Tax Administration and government are actively pushing through enactment of a tax code. The tax code is expected to be largely a compilation of the existing tax law. However, some tax policy changes are also considered.

Matthew Desborough-Hurst The Chancellor, Gordon Brown, gave his annual Budget on March 21 2007.

Jim Flaherty, Canadian Finance Minister: adamant the deduction will be removed Taxpayers in Canada are furious with the government over a plan announced in the budget in March to remove a provision that allowed interest expense deductions from investments abroad.