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Motorola, the multinational telecomunications company, could face an extra tax bill of up to $500 million after investigations by the US IRS into its tax returns for 1996 to 2000. A further probe for the years since then is still under way. The investigations centre on the company's transfer pricing practices.

Section 245 of the Income Tax Act (the Tax Act), enacted in 1988, contains a general anti-avoidance rule (the GAAR) that incorporates a modified business purpose test into Canadian tax legislation

Almost all of Germany’s 16 regional Länder have rejected calls to centralize tax collection in the country

Last Tuesday a team of five former Andersen partners left Ernst & Young in Luxembourg to join a team of 30 to set up a high-end, new international tax firm called Atoz

The Supreme Court of India has held that business income and capital gains earned by an Indian resident from immovable property in Malaysia cannot be taxed in India under the India-Malaysia tax treaty

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).