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  • The UK government launched HM Revenue & Customs (HMRC), the new tax body formed after the merger of the old Inland Revenue and Customs & Excise on April 18 2005.
  • The governments of the US and Bulgaria announced on April 21 that they plan to begin negotiating a bilateral income tax treaty. The first round of negotiations is scheduled to begin later this year. If agreed, the treaty would be the first ever between the two countries.
  • Beth Williams, a senior tax controversy and transfer pricing specialist, joined Baker & McKenzie's Palo Alto office on April 18.
  • Robert MacDonald: Switched firms after listening to a headhunter Gide Loyrette Nouel, a French international law firm, has started a US tax practice with the hire of Robert MacDonald in its New York office.
  • As part of the government's efforts to increase the number of countries with whom Oman has comprehensive double taxation avoidance treaties, Oman recently signed a treaty with Iran.
  • By Chris Atkins, Staff Attorney, Tax Foundation, Washington, DC
  • Mark Leeds: Prefers advising on tax from a law firm to an in-house tax role Mark Leeds, senior tax counsel at Deutsche Bank in New York, has left the investment bank to join Greenberg Traurig, an international law firm, as a shareholding partner.
  • At the time of the Budget, the HM Revenue and Customs announced a proposal to counter tax avoidance using arbitrage schemes that involve hybrid entities or hybrid instruments. The intention behind the proposed legislation is that it should apply where an arbitrage scheme using a hybrid entity or instrument results in:
  • Oliver Kächele, Markus Roth and Joachim Giehl Baker & McKenzie, McDermott Will & Emery and Haarmann Hemmelrath have all expanded their tax practices in Germany by hiring tax specialists from accounting firms.
  • The two ECJ judgments Lankhorst-Hohorst and Bosal Holding are causing thin-capitalization changes in Polish corporate tax. In 1999 thin-capitalization rules were introduced into the Polish tax system. These rules used to cover loans and credit provided by shareholders - Polish tax residents as well as non-residents.