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Peru's tax administration issued a resolution on September 18 2004 establishing new rules for taxpayer registrations in an effort to combat tax fraud. Government tax officials say that many businesses have been issuing false invoices with inaccurate registration numbers and registration numbers that do not exist.

The European Commission has approved Ireland's holding company regime, which provides for a tax exemption on chargeable gains arising from the disposal of shares, or assets related to those shares, in some subsidiaries. The regime is part of a package of measures designed to increase Ireland's attractiveness as a holding company location.

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.

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.

The recent decision of the European Court of Justice in the Manninen case (C-319/02) has significant implications for the UK's imputation system of dividend taxation.

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.

Mexico's President Vicente Fox has presented before Congress a bill to amend the Income Tax Law. This bill, which will be analyzed by Congress, includes a reduction in the income tax rate from the previously proposed 32% in 2005 to 30%, which will be reduced 1% each year until reaching 28% in year 2007.

When South Africa moved to the worldwide basis of taxing income and capital gains in 2000 and 2001, foreign dividends were taxed on a look-through basis. One traced the dividend through a chain of companies until the underlying profit was identified and a proportionate share of that profit was taxed in the South African shareholder's hands, with credit being given for foreign corporate and withholding taxes paid.

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

Pursuant to the 2004 tax law amendments, a real estate investment corporation (J-REIT) can hold 100% of the preferred investment certificates issued by a Tokutei Mokuteki Kaisha (TMK)