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PwC appoints Gene Donnelly to new role

PricewaterhouseCoopers has appointed Gene Donnelly to the newly created role of global managing partner-advisory and tax. He will focus on aligning the strategies, competencies and markets of the firm's Tax and Advisory service. He comes to the position from the US arm of PwC, where he was vice chairman-operations.

November 01 2005

Baker & McKenzie announces new key appointments

Baker & McKenzie, an international law firm, has made a series of high-profile appointments, almost doubling the size of its New York tax practice and appointing a former US Treasury tax legislative counsel to its Washington DC office.

November 01 2005

Why the sandwich structure problem needs innovative solutions

A recent IRS ruling (PLR 200532036) illustrates one solution to problems stemming from the all-too-common occurrence of a so-called sandwich in a cross-border holding company structure. The solution did not eliminate the sandwich, but used a section 355 spin-off to enable a foreign shareholder to claim an indirect foreign tax credit for taxes paid by a foreign subsidiary owned by the foreign shareholder's US consolidated group.

November 01 2005

Tax evolution in the Arabian Gulf

Popular perception of Arabian Gulf oil-rich states suggests that the region is a high-salary, free-spending and tax-free environment.

November 01 2005

Russian tax official arrested for accepting $1 million bribe

The deputy head of the tax service's banking department has been arrested by the FSB security police on a charge of demanding $1 million from the chairman of a Moscow bank to reduce the bank's tax bill.

November 01 2005

Court referral puts Emag issues in spotlight

The Emag VAT case gives the European Court of Justice the opportunity to offer fresh thinking on the concept of "static" and "moving" supplies as a tool for analyzing chain transactions, point out Henry Cairns-Terry and Simon Kirk of Ernst & Young

November 01 2005

IRS provides safe harbours for certain reorganizations subject to section 367(a)

Taxpayers transferring assets to a foreign corporation are required, under certain circumstances, to file a gain recognition agreement (GRA) in conjunction with the transfer. GRAs are generally required to obtain tax-free treatment for certain outbound transfers of corporate stock and securities subject to section 367(a). See Treasury Regulation section 1.367(a)-3.

November 01 2005

Italian government tightens participation exemption rules

The Italian government has published Law Decree No 203 in the Italian Official Gazette which has entered into force for all sales of qualifying shareholdings made from October 4. The decree has made a number of changes to the Italian participation regime. The most important of these involve the capital gains participation exemption being reduced from a 100% to a 95% exemption and the minimum holding period being extended from 12 to 18 months.

November 01 2005

French court rules on compatibility of tax consolidation regime with EC Treaty

A case has been brought in a French court questioning the compatibility of article 223A of the French Tax Code with the freedom of establishment. The rule stipulates that a company is not eligible for the tax consolidation regime unless 95% of its shares are held by the parent company.

November 01 2005

UK government releases new guide to tax credits

HM Revenue and Customs, in consultation with small business, has developed a new guide to R&D tax reliefs. The guide, which has been welcomed by tax consultancies and businesses, includes a flowchart that aims to help businesses to assess whether they have expenditure that might qualify for R&D tax relief. It also attempts to show businesses what to claim, how to claim and the pitfalls to avoid. It can be accessed via the HMRC's website.

November 01 2005

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