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On May 10 the Treasury Department issued Notice 2005-38, the second in a series of notices that provide guidance for US companies that elect to repatriate earnings from foreign subsidiaries to take advantage of the temporary reduced tax rate available under Internal Revenue Code (IRC) section 965. Section 965 enacted as part of last year's American Jobs Creation Act, provides for a special 85% dividends received deduction for certain dividend repatriations. The first round of section 965 guidance was issued in January as Notice 2005-10.

On April 1 a free trade agreement entered into effect between Mexico and Japan. The signing of this agreement has been well-publicized in Mexico as it is one of the first agreements of this nature signed by Japan with a developing country.

By Andrew Wholey, KPMG in the UK

Edmund Cohen, former head of Coudert Brothers' global tax practice, has left the firm for Winston & Strawn (W&S). He joined W&S' New York office last Monday, May 9.

Barbara Mace, formerly a partner and head of the US financial services transfer pricing practice at Deloitte, has moved to big-four rival Ernst & Young. Mace joined Ernst & Young's New York office on May 3 and will head the firm's financial service office's transfer pricing practice.

By Rodney Moore, KPMG in Australia

Gordon Brown: Will continue corporate tax consultation Gordon Brown, the UK Chancellor of the Exchequer, has assured business leaders that his government shares their objective of making the UK's tax regime internationally competitive.