Search results for

Richard Fletcher, a director of LECG, an economic advisory firm, has joined Baker & McKenzie in London as senior director - head of UK transfer pricing.

In Switzerland corporate income taxes are levied at two different levels: federal level and cantonal level. Whereas the income of a Swiss company (or a branch) is subject to the same direct federal tax rate throughout Switzerland, the cantonal tax rates vary. In 2005, for ordinary income taxes, the canton Zug was top of the list of the most tax favourable cantons, followed by Appenzell and other cantons in Central Switzerland.

Robert Green has left the US Internal Revenue Service to become a member of Caplin & Drysdale's international tax practice in its Washington, DC office. As director, international at the IRS, he was responsible for the US' cross-border negotiations and controversies with its treaty partners and dealt with other issues such as cost sharing.

Nearly 20 years after the US Congress enacted legislative changes to Internal Revenue Code section 863(d) and (e) in the Tax Reform Act of 1986, a new set of proposed regulations governing the characterization and source of income from space and ocean activities and international communications activities were released in autumn 2005. (Proposed Regulations sections 1.863-8(h) and 1.863-9(l).) These proposed rules replace a previous set issued in 2001.

Although a tax reform is expected in 2006, the Spanish government has recently announced a previous anti-avoidance reform that will affect various taxes. The text made public is a Bill that will probably go under extensive changes during its parliamentary proceedings, but its most significant proposals may be summarized as follows:

Ralph Cunningham asks five leading tax figures about what they expect to be the international tax trends and priorities in 2006

Foreign firms in China may face fewer tax benefits from late 2006, as the government implements reforms that target its corporate income tax policy. In January, China announced a plan to offer a number of tax incentives to facilitate social and economic development in 2006.

TN Pandey, a former chairman of India's Central Board for Direct Taxes, has said the country's fringe benefits tax should be reformed rather than scrapped

David Zaiken has joined Alvarez & Marsal Tax Advisory Services as a managing director in the firm's San Francisco office. He was previously a tax partner at KPMG on the US international tax and Asia Pacific supply chain teams. Before this he spent 26 years with Arthur Andersen as a tax partner and member of its global tax and supply chain teams.

Russell Nance and Gary Silverstein have been appointed special counsel in the tax department of Cadwalader Wickersham & Taft in New York. Nance advises on the tax aspects of debt and equity issuances, complex financial instruments, securitizations, collateralized debt obligations (CDO), and taxable and tax-deferred corporate acquisition and divestiture transactions. Silverstein represents issuers, underwriters, insurers and other parties on the tax aspects of mortgage-backed and asset-backed securities, real estate mortgage interest conduits and other debt issuances, including CDO and collateralized loan transactions.