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  • Adrian Crawford of KPMG says Irish politicians of all the main parties support the government's low tax model to attract multinationals to base themselves and their transactions in Ireland
  • The 10 most admired tax directors in North America, as voted by International Tax Review's readers, are a varied bunch. Between them they have more than 20 professional qualifications, with three being both qualified lawyers and certified public accountants. Their routes to the top have all been different. They tell Catherine Snowdon what has made them successful and what qualities a tax director needs to prosper
  • Value added tax – Exemption of the management of special investment funds – Concept of ‘special investment funds as defined by member states’ – Closed‑ended investment funds.
  • Paul Tamaki Wanda Rumball Prior to 2007, Canadian trusts and partnerships were given flow-through treatment for tax purposes. As a result, many public corporations converted into public income trusts in order to avoid tax at the corporate level.
  • A competitive tax regime and a proactive government should continue the growth in popularity of Ireland as a location for finance vehicles, believe Conor Hurley and Alan Heuston of Arthur Cox
  • Edward Tanenbaum US investment advisers willing to forgo favourable capital gains treatment may be able to defer recognition of incentive compensation fees in respect of foreign capital under management. However, the arrangement must comply with the complex rules of Code Section 409A, and take into account potential changes to those rules.
  • Svetlana Stroykova Introduced in 1999, the Russian transfer pricing legislation has not proven an efficient tool. The government officials believe a number of factors make the Russian transfer pricing rules "work improperly". In particular, officials cite the burden of proof of non – arm's length nature of prices applied by the taxpayers resting with the Russian tax authorities; the existence of the 20% safe harbour allowing the taxpayers to shift considerable profits offshore; the absence of penalties in case of a transfer pricing adjustment; and the lack of experience of the Russian tax authorities in understanding transfer pricing concepts as problems.
  • The Irish government has responded to competition for investment with an attractive mix of tax incentives and the growing treaty network, reports David Smyth, Joe Bollard and Rory MacIver of Ernst & Young
  • Welcome to the special feature on Ireland in the March issue of International Tax Review.