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The government released, on March 26 2004, a white paper aiming at improving the direct tax system

In the midst of considerable debate on the potential tax leakage from income fund structures, the Canadian government has introduced several changes affecting pension funds and non-resident investors in Canadian income funds. Income funds are tax-efficient structures that reduce or even eliminate entity-level tax. Investors hold units of a trust and are taxed on distributions from the trust. The 2004 federal Budget dampened the growing enthusiasm for such investments by penalizing certain classes of investors. Pension plans, which represent a significant pool of capital, are now subject to a monthly penalty tax when their investments in business income trusts exceed certain thresholds.

Some EU members have conformed with the Interest and Royalties Directive. Others will benefit from transitional arrangements. Philippe de Clippele and Benoit Verschueren of PricewaterhouseCoopers bring us up to date with the state of implementation

Jesus Barrios, director of taxes, Latin America for Oracle, says US and Japanese taxpayers need to be aware of two court decisions which could affect their businesses in Mexico

A survey of business confidence among middle market companies in the UK has found real concerns within the sector over taxation and the administrative burden.

By Andile Pama, general manager: communications, South African Revenue Service

Ken Bransom, the former head of Ernst & Young's US practice in Europe, has moved to Deloitte. Specializing in the US-European taxation of merger and acquisition planning and structured finance, Bransom joined Deloitte's London office on March 23 2004 and will work with a team of nearly 30 tax specialists led by Jeff Wehner that focuses on US companies with operations in Europe.

Kenneth Bezozo, a corporate tax partner at US law firm Haynes and Boone, was appointed co-head of the firm's newly-opened New York office on April 21 2004. Bezozo specializes in corporate, business planning and taxation matters including structuring, formations, mergers and acquisitions, dispositions and restructurings.

Stillson MacDonnell, a tax attorney at Littler Mendelson in San Francisco, was named chair of the employment tax committee of the tax section of the American Bar Association on April 22 2004. MacDonnell specializes in ERISA and employment tax and has successfully handled numerous employment tax audits and litigation before the IRS.

The special Canary Islands Special Zone (ZEC) tax regime has been in force since 2000 after authorization by the EU authorities. After being in effect for almost four years, this is a good time to weigh up and recall the main advantages and to analyze the level of success and attainment of its objectives.