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US law firm Milbank, Tweed, Hadley & McCloy on May 12 2004 hired two tax lawyers from Freshfields Bruckhaus Deringer to start up a new office in Munich. Rolf Füger specializes on tax and finance structuring for private equity firms. Norbert Rieger, the other hire, has a corporate tax background.

The UK Chartered Institute of Taxation appointed John Beattie as its new president on May 21 2004. Beattie served at the Inland Revenue before joining KPMG in 1979. Peter Kempster, a tax consultant at Nabarro Nathanson in London, was appointed deputy president. John Cullinane, a tax partner at Deloitte in London, was appointed vice president.

The government has finally published, in draft, details of the types of arrangement that will be subject to the new tax planning reporting requirements announced in the March 2004 Budget. The rules will focus initially on employment tax planning, use of financial products and VAT planning.

US taxpayers recently scored an important victory in Dover Corp v. Commissioner, which has monumental ramifications in the US tax treatment for disposing of non-US operations.

When a non-resident individual is planning to make long-term investments in Spain, they should not forget to analyze the tax implications that may eventually arise for the heirs. We refer to the Spanish inheritance tax.

The debate on tax amnesty has been going on for more than ten years. The following initiatives are currently being discussed:

The UK Inland Revenue's tax avoidance regulations, published on May 17 2004, have been met with universal condemnation from tax lawyers and accountants. The draft rules require promoters of certain transactions to notify the Inland Revenue when they are made available to clients.

The new Japan-US tax treaty provides that the contracting states shall conduct transfer-pricing examinations of enterprises and evaluate applications for advance pricing arrangements in accordance with the OECD Transfer Pricing Guidelines. In connection with this policy, a new methodology for an arm's-length price, transactional-net-margin method (TNMM), which is provided by the guidelines, has been introduced by the Japanese 2004 Tax Reform, as one of the acceptable methods in calculating the arm's length price.

The Mumbai Tribunal in Maharashtra State Electricity Board v. DCIT (83 TTJ 325), examined applicability of the old India-UK Double Tax Avoidance Treaty (DTAA), which was substituted by new DTAA in 1994, to fees received by a UK-based firm of solicitors for legal services provided to an Indian company.

The Canadian Supreme Court decision last year in Markevich v. The Queen affirmed that federal limitation periods may limit collection of long-outstanding tax debts. However, many advisers speculated that the taxpayer's victory would be temporary at best given the Crown's public requests that the law be changed.