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William Chip: Covington & Burling has a

Toronto, where Rand and Thomson will work for Stikeman Elliott The increasing aggression of the Canadian tax authorities has led to higher-value disputes and prompted two tax litigation specialists to leave their boutique firm to rejoin Stikeman Elliott, one of the country's largest law firms.

A new internal study by the US Treasury Department has confirmed that Internal Revenue Service (IRS) agents are demanding transfer pricing documentation in many more audits. In January 2003 the IRS published an internal directive requiring its auditors to request transfer pricing documentation in all audits with international transactions. The new study compared audits before and after the directive. Before the directive, documentation was requested in 35% of the audits studied, afterwards the number rose to 55%.

An important (albeit often unnoticed) feature of Spanish tax law is the responsibility regime of representatives of permanent establishments and of foreign partnerships and similar entities with a presence in Spain. Since January 1 2003 these representatives are jointly and severally liable for the tax debts of their principals.

The domestic production deduction is a significant element of the new US corporate tax legislation. It has transfer pricing implications which are not yet completely clear, explain Sean Foley, Anne Welsh and Thomas Herr of KPMG LLP (US)

Representatives of the US and French governments signed protocols on December 8 2004 amending the 1994 France-US income tax treaty. The treaty protocol addresses the complicated treatment of cross-border partnerships by including flexible form-of-entity rules that will reduce the risk of double taxation for US investors in France.

Hermann Eber-Huber, a former tax partner at Linklaters, has left the multinational law firm to join the Frankfurt-based finance boutique Smeets Haas Wolff. Eber-Huber specializes in tax consultancy, M&A and the taxation of real estate.

Grant Thornton, an international tax and accounting firm, promoted Jeffrey Olin to national partner-in-charge of international tax services on December 6 2004. Olin specializes in cross-border tax planning.

Duncan Baxter, a former senior tax partner with Deloitte in Melbourne, has moved to Blake Dawson Waldron (BDW), a law firm, to lead their direct tax practice. Specializing in corporate and international tax, Baxter will focus on M&A, divestments and restructures. BDW announced the move on December 2 2004.