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The chief counsel of the Internal Revenue Service (IRS) in Washington, DC has disputed findings in a report from Citizens for Tax Justice (CTJ) and the Institute on Taxation and Economic Policy (ITEP) released in September 2004

Inter-company aid is the source of much dispute between companies and the French tax authorities, and has, over time, led to the French Supreme Administrative Court, defining a whole set of criteria regarding deductibility

Donald Korb, the US Internal Revenue Service (IRS) chief counsel, used his keynote address at International Tax Review’s fourth Global Transfer Pricing Forum in Berlin on September 29 2004 to promote the benefits of the US’ advance pricing agreement (APA) programme

India’s Central Board of Direct Taxes (CBDT) has released a circular to dispel the long-running confusion over the taxation of business process outsourcing (BPO)

By Peter Cussons, international corporate tax partner, PricewaterhouseCoopers, London

The Internal Revenue Service (IRS) and US Treasury Department have issued proposed regulations under IRC section 269B addressing when a stapled foreign corporation will be treated as a US corporation for various purposes (regulation 101282-04). Two or more corporations are treated as stapled entities when more than 50% of the value of the shares of the corporations are subject to restrictions that require their shares to be transferred together.

According to the Belgian income tax code, the taxation of capital gains realized by individuals as substantial shareholders on the sale of shares in Belgian companies depends on the residence of the acquirer. If the acquirer is a foreign company, the capital gain will be (subject to further conditions) taxable in the hands of the vendor. However, if the acquirer is a Belgian company and certain anti-avoidance conditions are satisfied, the capital gain is tax exempt. These rules complicate acquisition structures by the need to interpose a Belgian acquisition vehicle.

George Gillham, a former inspector of taxes with the UK Inland Revenue, joined the law firm Dorsey & Whitney on September 6 2004. Gillham will work with Philip Martin, a high-profile tax litigator and former tax director at the retail company Marks & Spencer.

US law firm Greenberg Traurig hired Michelle Ferreira, a former Internal Revenue Service (IRS) litigator, as of counsel on September 8 2004. During her eight-year tenure in the IRS attorney's office Ferreira tried more than 24 cases. She will specialize in estate tax planning at Greenberg Traurig.

Companies seeking tax advice from chartered accountants in New Zealand will get greater privacy after the country's finance ministry announced new rules to level the playing field between accountants and lawyers.