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The Treasury Department and IRS have released temporary regulations (TD 9240) – and by cross-reference, proposed regulations (REG-106418-05) – modifying the rules for determining whether a controlled foreign corporation's (CFC's) distributive share of partnership income is excluded from foreign personal holding income (subpart F Income) under the active insurance business exception contained in Internal Revenue Code section 954(i). These temporary regulations modify a rule included in the so-called "Brown Group" regulations (as finalized in 2002) regarding the application of section 954(i), and specifically will affect CFCs that are qualified insurance companies that have an interest in a partnership, as well as the US shareholders of the CFCs.

The South African government announced plans for an advanced ruling system and legislation on a general anti-avoidance rule in its budget on February 15

Draft regulations dealing with the taxation of authorized investment funds were introduced in the UK parliament on February 13

Baker & McKenzie have hired three senior-level economists for its global transfer pricing practice and economics group in the US. Brian Cromwell, formerly of Ballentine Barbera, will become principal economist in the Palo Alto office. He has a particular focus on transfer pricing matters involving advance pricing agreements, audit defence, intangible property valuations, and global transfer pricing strategies. Phil Carmichael, formerly a managing director of KPMG's economics and valuation services practice in New York, joins Baker & McKenzie's economics group in the same city as a director, as does Michelle Martinez in Chicago. Martinez was KPMG in Chicago's managing director for major transfer pricing projects involving large US, European and Asian multinational clients.

The reinvestment tax refund policy is a well-known tax incentive granted to foreign investors in China where foreign investors may enjoy up to a 100% corporate income tax refund on its direct re-investment in other foreign invested enterprises (FIEs), made with the profits realized from their existing investments in China. Such a policy was firstly launched in 1993 with the obvious intention to encourage foreign direct investment (FDI) into China.

Article 45 section 2 of the Belgian value-added tax code has stipulated for many years that input VAT on cars is restricted to 50%. Only in a very limited number of cases will full VAT deductibility be allowed, for example, for car leasing or car selling.

Welcome decisions from the Belgian Ruling Commission provide guidance on how to approach transparency for Belgian tax purposes believe Kurt De Haen and Frederique Bearzatto of PricewaterhouseCoopers

According to a new report, the UK is at risk of becoming increasingly uncompetitive for investment.