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DLA Piper's Carlos Rodríguez Barrigüete in Madrid and Eric Ryan and Bernhard von Thaden in California explain how taxpayers should prepare for the new rules

Tax directors and advisers came to Hong Kong in November for International Tax Review's first Asia Tax Awards

Comprehensive reform of global financial structures may be required if capital flight and the resulting tax evasion is to be stopped, believes David Spencer

Japanese government officials are divided over plans to eliminate capital gains and dividend income tax breaks. But parliament appears to have resolved rows over plans to cut the corporate income tax rate.

Romano Prodi, the Italian prime minister, has pledged to crackdown on tax evasion in the 2007 Budget and will open up the economy with reforms to encourage M&A.

Sean Foley The Treasury Department and IRS have released new proposed regulations regarding the determination of the income and currency gain or loss of a section 987 qualified business unit (QBU). The intention is to prevent taxpayers from recognizing what are considered to be non-economic foreign exchange losses. The proposed regulations withdraw the existing proposed rules, which were issued on September 25 1991.

The UK tax authorities Her Majesty's Revenue & Customs (HMRC) have published draft guidance on the effect of the Indofood decision (Indofood International Finance Limited v JP Morgan Chase Bank NA, London Branch). This may have implications for cross-border financing structures, particularly on-lending structures, which rely on a double taxation convention (DTC) to eliminate UK withholding tax on interest. The draft guidance focuses on the interpretation of beneficial ownership in the context of such DTCs. To benefit from the terms of such a DTC, it is usually a requirement that the recipient of the income in question is the beneficial owner of it. The guidance indicates that HMRC will be adopting a narrower interpretation of beneficial ownership (which HMRC refer to as the international fiscal meaning) in the context of DTCs than its general meaning in UK tax law. HMRC indicate that in order to be the beneficial owner under the "international fiscal meaning" it is necessary that the recipient "enjoys the full privilege to directly benefit from the income". Employing this definition may prejudice the availability of treaty relief.

Maire Walsh Residents of Zug, a Swiss canton, voted in favour of a revision of the Cantonal Tax Law. The following changes represent the most relevant of the revisions and will come into effect on January 1 2007.

Jacek Bajson Poland's revised Personal Income Tax (PIT) will enter into force on January 1 2007.

FASB has tried hard to address the question of uncertain tax positions. But its new standard fails to deal with all the issues, believe Hira Sharma of Chiltern, and Jim Eberle of Alvarez & Marsal