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In December 2004, the EU Council of Ministers agreed on proposals to amend the EC Mergers Directive to improve the relief available to companies operating in Europe. The most important changes to the directive are as follows:

The "butterfly reorganization" is the name in Canada for the type of reorganization by which a Canadian corporation, call it the distributor, can distribute property to one or more of its corporate shareholders on a tax-deferred basis. These reorganizations can be done by private corporations or public corporations, and can take the form of a "split-up", whereby one or more shareholders receive their share of the distributor's assets and cease to be shareholders of the distributor, or a "spin-off", whereby the distributor makes a distribution to a new corporation owned by the same shareholders as the distributor and in the same proportion. In 2001, rules were introduced to facilitate spin-offs by public companies. The Department of Finance has now recommended further amendments to the Federal Income Tax Act to provide additional relief for public company spin-offs.

PricewaterhouseCoopers

Last December the Argentine executive has promulgated the Law 25988 (passed by the Congress on December 16 2004) that enables taxpayers to recover value-added tax (VAT) paid on certain acquisitions of fixed assets and establishes a one-year extension of the unpopular financial transactions tax among other tax measures.

The US Tax Court has dealt with litigation worth hundreds of million of dollars and a few thousand dollars during its 81-year existence. Joel Gerber, its chief judge, spoke to Ralph Cunningham about how he and his colleagues operate and his more than 20 years as a judge

The new Belgian collateral and securities lending tax legislation is an attempt to create consistent rules for this type of transaction, explain Kurt De Haen and Jessica Win of PricewaterhouseCoopers

The new year has just begun and already the European Commission has published two pieces of research on company tax. And despite the low number of participants in each survey, the Commission believes they reflect enough support for increased corporate tax cooperation.

Multinational companies with operations in China will continue to benefit from the country's tax system after the Chinese government pledged to keep preferential corporate tax treatment for foreign businesses until at least 2007.

Deloitte & Touche/Hana have concluded their merger negotiations with Anjin Deloitte. Since April 2002 the two firms had been operating as one firm as far as the law allowed with a memorandum of understanding arrangement. The merger was completed on January 30 2005.

Berkowitz Dick Pollack & Brant (BDPB), a second-tier public accounting firm with two offices in the US state of Florida, has expanded its international tax practice with the hire of Cary Cabañas, a former KPMG international tax senior manager.