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David Mayo has Paul, Weiss in New York as a partner in the tax partner. He had previously been a partner of Gibson, Dunn & Crutcher for more than eight years.

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.

The Chilean IRS confirmed through a couple of recent rulings that the legal provision which prevents the IRS from exercising its authority to appraise the values used in a transaction within a reorganization process is applicable to non-Chilean entities.

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

The WTO's Appellate Body has upheld the EU's complaint that the US is continuing to maintain foreign sales corporation and extra-territorial income subsidies that the WTO has previously declared illegal.

Axa Asia Pacific is suing the Australian Taxation Office (ATO) over a A$127 million ($94 million) tax bill. The dispute originated from the ATO's treatment of the financial services company's income after the sale of Axa's health insurance business in 2002. Axa is now requesting that the court either reverses the authority's decision or reduces the company's taxable income for 2002 by A$383.1 million

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.

According to the International Herald Tribune of February 14, the US tax authorities are offering law firms, accounting firms, banks and investment firms that put together aggressive tax schemes a chance to "come forward, pay penalties and turn over information" and avoid criminal prosecution

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