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David Laro, a judge at the US Tax Court ruled on April 18 that the tax shelters known as the Son of Boss are invalid. Son of Boss refers to shelters such as foreign leveraged investment programmes (FLIPS), offshore portfolio investment strategies (OPIS), bond linked issue premium structures (BLIPS) and market linked deposits (MLDS). The first three structures are at the centre of the government's tax shelter litigation against ex-KPMG employees.

Three advisers - Stephanie Pantelidaki, Martin Zetter and Andrew Boyle - joined the London office of Baker & McKenzie from LECG. Pantelidaki will be an assistant director, Zetter a senior consultant and Boyle an economist. Richard Fletcher made the same move in January.

The Internal Revenue Service (IRS) has just released Notice 2006-35 stating that branches of financial institutions will no longer be permitted after December 31 2006 to act as Qualified Intermediaries in countries that do not have IRS-approved "know your customer" (KYC) rules.

The tax authorities have released a draft circular on the taxation of internationally mobile employees. The final version will be published officially within the next few weeks. The circular brings a number of decrees from the past few years together in a single document, and so serves as a good overview of the special features of expatriate taxation.

Lone Star, a US investment fund, has donated W100 billion ($106 million) to Korea from the profits of the sale of Korea Exchange Bank. The Korean authorities are investigating Lone Star as part of a tax probe into offshore funds, which began on April 24

Linklaters carried off four awards at International Tax Review's European Tax Awards 2006 in London, including the most prestigious prize of the evening for European tax firm of the year

Michaela Klar has joined Wolf Theiss' tax practice in the firm's Vienna office. As well as corporate tax law and international tax law, she specializes in the taxation of financial instruments. She previously worked for Freshfields Bruckhaus Deringer.

The Luxembourg Administrative Tribunal in a decision released on March 13 2006 (No 19691) clarifies when a holding 1929 company converted into a fully taxable company becomes subject to Net Worth Tax (NWT) in Luxembourg (companies benefiting from the Holding 1929 regime are exempt from this tax).

The EU's policy on transfer pricing documentation requires more information than its Dutch equivalent. Taxpayers should consider the benefits of following the European model, believe Monique van Herksen and Folkert Idsinga of Baker & McKenzie

The South African finance minister, Trevor Manuel, said on April 3 that he would soon name a task force to decide how to best implement a windfall tax on petrochemicals company Sasol. Sasol which was state subsidized, announced an increase in profits of about R2.9 billion ($480 million) because of higher oil prices in the last half of 2005. The windfall tax is popular politically because it will lead to a redistribution of income but tax professionals are concerned about its introduction. Sasol is expected to contest the committee's proposals but it is predicted the authorities will pass a law before the end of 2006.