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  • Freedom of establishment – Corporation tax – Payment of dividends – Exemption for dividends paid to resident companies – Withholding tax levied on dividends paid to non-resident companies – Double taxation convention – Possibility of setting off the amount withheld against tax due in another member state.
  • Peter Orszag, the co-director of the Tax Policy Center, a joint venture between the Urban Institute and the Brookings Institution in Washington, has been nominated to become director of the Congressional Budget Office
  • Eric Solomon has become the Internal Revenue Service's assistant secretary for tax policy, a position he has held unofficially since 2004. Solomon will be responsible for policy analysis, advice on international issues of federal taxation, regulatory guidance, and tax treaties.
  • Four of Mayer Brown Rowe & Maw's 39 new partners are from the tax practice. Olivier Parawan, a private equity/LBO and cross-border acquisitions specialist, becomes a partner in Paris; Heiko Penndorf, from Frankfurt, does banking products work, particularly securitisation, structured finance and real estate finance; Jeffrey Bruns, a tax transactions partner in Chicago, works on the formation and operation of partnerships and limited liability companies, particularly on transactions involving real estate assets and Nathaniel Carden is a tax controversy and transfer pricing specialist
  • The UK chancellor's Pre-Budget Report (PBR) has reversed some of the implications of Deutsche Morgan Grenfell's (DMG) victory against the UK authorities, which entitled companies to compensation for overpayment of corporation tax.
  • Mike Durst, a leading name in transfer pricing in the US, has left PricewaterhouseCoopers for the second time.
  • Tax professionals say diplomacy led the European Court of Justice (ECJ) to give incorrect and convoluted verdicts in the franked investment income (FII) and advance corporation tax (ACT) group litigation cases.
  • Freedom of establishment – Free movement of capital – Directive 90/435/EEC – Corporation tax – Payment of dividends – Prevention or mitigation of a series of charges to tax – Exemption – Dividends received from companies resident in another member state or a non‑member country – Tax credit – Advance corporation tax – Equal treatment – Claim for repayment or claim for damages.
  • The UK tax authorities have insisted that changes to controlled foreign company (CFC) rules comply with the European Court of Justice's decision in the Cadbury Schweppes case.
  • Freedom of establishment – Free movement of capital – Corporation tax – Payment of dividends – Tax credit – Separate treatment of resident and non-resident shareholders – Bilateral double taxation conventions.