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The US Treasury's former deputy international tax counsel has moved to private practice after a two-and-a-half-year stint in government.

Representatives of the member firms of Taxand An alliance of tax firms has come together in Europe, India and the US to provide their clients with independent tax advice on international tax. Taxand will be a non-exclusive network of tax firms which will work with each other when possible.

Andrew Needham, a former tax partner at Willkie Farr & Gallagher, has become Cravath, Swaine & Moore's first lateral hire for 62 years. His move is the first time since 1943 that Cravath, Swaine & Moore has recruited a partner from outside the firm. Needham has advised clients including Zurich Insurance Company, Midamerican Energy Holdings and Teva Pharmaceuticals. He will join his new firm on April 4 2005.

Patrick Bignon:

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.

Corporates can expect some far-reaching changes in the tax arena in Spain. Among the initiatives recently announced, which will be embodied in legislative changes in the short term, reference may be made to the approval by the Council of Ministers on February 25 2005 of the first package of measures of the Plan for the Dynamization of the Economy.

Interest on loans entered into by a foreign head office and allocated to a Russian permanent establishment (PE) is considered to be sourced from Russia under most double tax treaties (DTTs) concluded by Russia. Therefore such interest is subject to Russian withholding tax (WHT) at the rate of 20%. This rate is reduced to 0% under most DTTs (Russia's treaties with the US, UK, Luxembourg, the Netherlands and Cyprus). However, under certain DTTs (Russia's treaties with Italy and Switzerland), the WHT rate is reduced to 10% or 5% and therefore it is necessary to pay WHT.

The tax features of securitizing assets through Ireland give the country many advantages in establishing a worldwide reputation for this type of transaction, argue Enda Faughnan and Harry Gleeson of PricewaterhouseCoopers

The Irish government and revenue authorities continue to refine the tax regime for finance vehicles. The changes can only help to boost the appeal of the structures, believe Fintan Clancy, Caroline Devlin and Conor Hurley of Arthur Cox