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Andrés Edelstein Ignacio Rodríguez After Congress approval, on December 21 2006 the Argentine Executive Branch has enacted the Double Tax Treaty signed with Russia (Law 26,185).

Michael Friedman and Todd Miller of McMillan Binch Mendelsohn identify the challenges and tax-planning opportunities that the new SIFT rules raise for non-resident investors

On their bikes? Foreign firms expected to stay following reform Following years of speculation, China's National People's Congress (NPC), the country's parliament, looks set to pass a bill unifying the tax codes for foreign and domestic companies in 2007. A merged code could come into force at the beginning of next year.

Two notices on Subpart F reform are the latest attempts to provide taxpayers guidance on issues that were uncertain.

Wal-Mart, the world's biggest retailer, has concluded the first advance pricing agreement (APA) with the State Administration of Taxation (SAT) in China and the US Internal Revenue Service (IRS).

Hal Hicks, international tax counsel of the US Treasury, is stepping down on February 6 to become an international tax partner in the Washington, DC office of Skadden, Arps, Slate, Meagher & Flom. He will be working on international tax support for transactions, tax consulting and tax controversy.

Akio Takisaki On December 14 2006, the 2007 tax reform proposals were released. Among the various items proposed, we have set out the main points specifically regarding international taxation as below:

Massimo Agostini The Italian Financial Act 2007, enacted December 27 2006, has introduced a new real estate investment vehicle called Società d'investimento immobiliare quotata (SIIQ). It is expected to become the Italian equivalent of, among other things, the US's Real Estate Investment Trusts and the French Societè d'Investissment Immobilier Cotee.

Nelio Weiss Philippe Jeffrey For a second consecutive year and with the objective to minimise the effect for exporting companies from the appreciation of the local currency in relation to foreign currencies (specifically the US dollar and the Euro) the Brazilian authorities issued on December 29 2006, Ordinance 425 and Normative Instruction 703. The directive amended the Brazilian transfer pricing legislation. As per the latter Ordinance and Normative Instruction, Brazilian exporting companies will be allowed to increase their export revenues for calendar year 2006 (for transfer pricing calculation purposes) using the ratio of 1.29. This exceptional measure will only apply for the fiscal year 2006. As mentioned, a similar measure was also adopted for fiscal year 2005, allowing the Brazilian exporting companies to increase their export revenues using then a ratio of 1.35.

Sec 911 has changed the tax treatment of US expatriates. Edward Gibbons and Leann Balbona of KPMG in the US reveal that housing is only one area where expats and employers may have to rethink their assignment strategies