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  • Tonucci, the Italian law firm, will increase its tax capability on September 1 2004 when it will merge with Studio Grimaldi & Associati, a renowned tax boutique. The move will see the boutique's 10 tax professionals, who specialize in domestic and international tax planning, join Tonucci under the leadership of Piero Alonzo and Gian Marco Committeri.
  • The Indian Central Board of Direct Taxes (CBDT) released a draft circular last Mondaythat refines the hazy definitions over the taxation of business process outsourcing (BPO) by multinational companies
  • Two months after announcing plans to address certain "inappropriate foreign tax credit transactions," (see International Tax Review, US Outbound Update, April 2004, p97), the US Treasury Department and the Internal Revenue Service (IRS) issued long-anticipated temporary and proposed regulations governing partnership allocations of creditable foreign taxes under Internal Revenue Code section 704(b). Under these regulations, an allocation of creditable foreign taxes cannot have substantial economic effect and as such the taxes must be allocated in accordance with the partners' interests in the partnership.
  • Guillermo Pérez, former national director of tax services at Pistrelli Henry Martin y Associados, Ernst & Young’s member firm in Argentina, has taken early retirement.
  • The success of Deloitte’s UK tax practice in the last year has boosted average partner profits across all the firm’s service lines. Figures released on August 5 2004 show that partners earned an average of £621,000 ($1.13 million).
  • New York is rife with rumours of two different groups of former Andersen tax partners looking to set up specialized corporate tax boutiques in the US. After the demise of Andersen in 2002, most the firm’s tax advisers in the US joined Deloitte and Ernst & Young.
  • Marc De Munter, formerly a tax specialist with Freshfields joined DLA’s Brussels office last week. Joining the firm’s expanding tax practice, De Munter will work alongside Dirk Caestecker and Jeroen Gobbin. DLA is expanding their tax services and now has 95 lawyers in their Brussels office.
  • The big four firm has lost Richard Snowden who left to head up Henry Davis York’s tax practice. Snowden specializes in banking and financial services. Snowden cited restrictions in the US on accounting firms providing non-audit services to audit clients as one of the reasons for his move.
  • The US Treasury and the Internal Revenue Service issued proposed regulations last Thursday providing guidance for determining a US shareholder’s pro rata share of income for controlled foreign corporations (CFCs) under the subpart F rules. The proposed regulations provide detailed rules on distributions of earnings when a CFC has multiple classes of stock. When issued in final form the regulations will be effective for tax years beginning January 1 2005.
  • The new accounting standard for the impairment of fixed assets will go into effect for fiscal years starting on or after April 1 2005. However, since early adoption was permitted for fiscal years ending on or after March 31 2004, some companies have already adopted the new standard.