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  • Cole & Partners, a Canadian business valuation and financial litigation firm, has started a transfer-pricing practice with the hire of David Kemp from KPMG. Kemp has 13 years' experience advising multinational enterprises on transfer-pricing planning, documentation and dispute resolution.
  • Peter Spori, a new tax consultant at Prager Dreifuss, the Swiss law firm, said that he left Ernst & Young because he wanted to keep working. The big four accounting firm has a retirement age of 60 for its partners. But Spori, who is approaching that age, revealed in an interview with International Tax Review that wanted to keep working.
  • The US Treasury Department recently released its detailed tax proposals for the fiscal year beginning October 1 2005. Two of the proposals would affect cross-border transactions.
  • In recent months several well-known publicly-traded corporations have used section 355 tax-free split-offs to redeem out, in effect, large minority shareholders. The Bush administration's financial year 2006 Budget proposals include a proposal to stop, or at least slowdown, the "cash rich D" split-offs.
  • Back in 1982 the Supreme Court ruled that a gain realized on conversion of a convertible bond could not be seen as a benefit derived from shares and consequently such gain was not eligible for the participation exemption, even where the holder of the bond already had a qualifying interest in the share capital of the issuer. At the time, this ruling was subject to some criticism, but obviously with no avail to the tax practice.
  • Sed Crest discovers how tax directors in North America are dealing with the Sarbanes Oxley Act and why they are less than satisfied with the tax advice they receive
  • Issues concerning transfer-pricing methodology in the Japan-US Tax Treaty should have a significant effect on audits and the advance pricing agreement process, believes Kazuo Taguchi, of Baker & McKenzie
  • In 2004 the OECD released a study on transfer pricing issues arising from employee stock option plans. Gareth Green of Transfer Pricing Solutions, William Franklin of Pinsent Masons and Mike Heimert of Ceteris consider what can be learned from it