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Los Angeles-based international investment bank, Houlihan Lokey Howard & Zukin, released its transfer pricing growth strategy today, after aggressively hiring transfer pricing professionals from the big-four professional services firms, particularly Ernst & Young.

The American Bar Association (ABA) has appointed Reginald Clark, a partner of Sutherland Asbill & Brennan's tax practice in Atlanta, to the position of chair of the corporate tax committee in the section of taxation for 2005-2006. Clark's practice at Sutherland is focused on corporate taxation, M&A and restructuring. At the ABA he will be responsible for coordinating all the committee's activities.

Kenneth Simon, former vice president of taxes at Avon Products, has moved to a similar position at Herbalife, a global network marketing company that sells nutritional supplement and personal care products.

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.

Under the forthcoming comprehensive revision to the Japanese corporate law, the law establishing the limited liability company known as the Yugen Kaisha (YK), which is an eligible entity under the so-called check-the-box regulations (CTB Regulations) will be repealed.

VAT – Article 19 of the Sixth VAT Directive – Deduction of input tax – Property transactions – Goods and services used for both taxable and exempt transactions – Deductible proportion.

By Andrew Wholey, KPMG in the UK

By John Carver, KPMG in Switzerland

By Peter Dolan, Global Partner-in-Charge, International Executive Services, KPMG