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  • John Cullinane, the new leader of the UK's tax advisers, has taken on the task of boosting the standing of the profession and encouraging the government to stick to the rule of law in the tax system. He explains to Ralph Cunningham how he will achieve results
  • Kevin Rowe of Alston & Bird compares the Alcatel-Lucent merger with the DaimlerChrysler merger of 1998 and assesses how their structuring ensured tax-free status for each merger of "equals"
  • US tax practitioners believe that the new Subpart F look-through rule for interest, dividends, rents and royalties transferred between controlled foreign corporations (CFCs) will be very significant to US multinationals. The measure was contained in the Tax Increase Prevention and Reconciliation Act of 2005 (HR4297), signed by President George W Bush on May 17.
  • By Jos Peters, Rima Marlyn
  • To date Spain has signed 64 tax treaties. Over the past twelve months, the Spanish tax authorities have been working hard to increase this figure. Three of those 64 tax treaties became effective within this period: Algeria, Macedonia and Vietnam. In this same period, Spain almost concluded negotiations with 12 additional countries. However, the relevant tax treaties have not yet come into force (they are initialled, signed or awaiting parliamentary approval).
  • The Polish minister of finance has set up the e-taxes project. An amendment to the Polish Tax Ordinance Act, which comes into force as from August 16 2006, introduces an obligation (for some groups of taxpayers) and possibility (for the remaining taxpayers) to communicate with tax authorities electronically. After this date delivering of the tax returns in the electronic version will be compulsory for public bodes, courts, bailiffs and notaries as well as some specific taxpayers such as:
  • The Mexican Senate has recently approved several amendments to the Mexican Federal Tax Code (MFTC), which are pending to be published in the Official Gazette.