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  • Liechtenstein, Monaco and San Marino signed savings tax agreements with the EU in Brussels on December 7 2004 . The three countries are the last of the five non-EU states whose participation is required, according to the terms of the EU Savings Tax Directive.
  • 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.
  • The US tax system benefits from a healthy interchange of tax professionals between the Treasury and the IRS on the one hand and law and accounting firms on the other. Many tax specialists, such as Deborah Harrington, remain in government for three or four years before returning to private practice. Harrington returned to Deloitte on November 19 2004.
  • Laszlo Kovacs: Advocates a common consolidated tax base for the EU The new EU commissioner for taxation and customs union is sticking to European Commission orthodoxy on corporate tax.
  • There are various entity forms of doing business in foreign countries that exist between corporate form and the kumiai form. The Japanese tax treatment for each entity form is unclear. Especially regarding US limited liability corporations (US LLCs) and US limited partnerships (US LPs), there are no clear guidelines to help determine whether these entity forms are subject to corporate level taxation or pass-through taxation for purposes of Japanese taxes.
  • The Advocate General has given an opinion in a case known as "D" that certian wealth tax relief in the Netherlands is contrary to EC law as it was only available to Dutch residents or under certain double tax treaty provisions. The taxpayer, D, a German resident, was denied from the relief as he was not a Dutch resident. The tax treaty between Germany and the Netherlands did not include an entitlement to the relief, whereas the Netherlands' treaty with Belgium did allow the relief to Belgian residents.
  • The Capitol, Washington, DC After campaigning on tax reform as a priority for his second term and winning greater majorities in the both the House of Representatives and the Senate, President George W Bush looks well-placed to further advance his tax reform agenda, which could include a new federal consumption tax.
  • Kristian Jensen, the Danish minister of taxation, has published draft legislation to tighten the country's transfer- pricing regime. The stringent proposals, intended to comply with the EU principle of freedom of establishment, would introduce documentation requirements for domestic as well as cross-border transactions.
  • Two decisions from the House of Lords, the UK's highest court, have failed to give definitive guidance on tax avoidance in the UK. In the Scottish Provident case, which the Inland Revenue won, the law lords ruled on November 25 2004 that a court may need to consider a series of transactions when applying a tax law. But in a separate ruling on the same day, the Inland Revenue lost a verdict to Barclays Mercantile which confirmed that business purpose may not be necessary to enjoy a tax benefit. See the February 2005 issue for full-length feature.