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  • The government released, on March 26 2004, a white paper aiming at improving the direct tax system.
  • Following the example of other European countries, Italy has adopted a special tax regime for the income deriving from the use of certain vessels, having a net tonnage higher than 100 tons, under the form of so-called tonnage based corporation tax (the Tonnage Regime), pursuant to the new articles from 155 to 161 of the Italian Tax Code (ITC), as amended. More precisely, the Tonnage Regime will enter into force as soon as:
  • After a decade of pondering, the German tax authorities have issued a Directive defining their position on the classification of US limited liability companies (LLCs) as corporations or partnerships for German tax purposes (Directive of March 19 2004). The Directive establishes no general rule or presumption in favour of one result or the other, but does identify the relevant factors for case-by-case analysis.
  • The German government has issued administrative guidance on the German tax treatment of US LLCs. Each case still must be examined on its own facts, argue Norbert Endres and Andreas Kowallik of Deloitte
  • Tax specialists and corporate taxpayers have reacted with dismay to the unclear measures to introduce intra-UK transfer pricing regulations and a crackdown on tax avoidance schemes in the UK Finance Bill. The UK Treasury released the 584-page Finance Bill for its first parliamentary reading on April 8 2004.
  • The Brazilian Senate is considering changes to the tax treatment of foreign imports, due to come into force this year, that could benefit companies in the automotive and pharmaceutical industries. Provisional Measure 164 which levies Program for Social Integration contributions (PIS) and Contribution for the Financing of Social Security (COFINS) on imports of goods and services, will take effect on May 1 2004.
  • The US Senate is no closer to breaking the gridlock over a bill to repeal the FSC Repeal and Extraterritorial Income Exclusion Act (ETI Act), Senate leaders indicated on April 20 2004. Progress appeared to have been made on April 8 when initial amendments were agreed. That compromise could set the process back further, however, as more than 80 amendments were listedthe list of amendments ran to over 80 in number.
  • Richard Stamm will be the new head of PricewaterhouseCoopers' US tax practice from July 1 2004. Stamm joined Pricewaterhouse-Coopers in 1976, is a member of both the US and global tax leadership teams and oversees each of PricewaterhouseCoopers' specialized practice units. He will replace Rick Berry who will retire at the end of the firm's fiscal year.
  • International law firm Greenberg Traurig expanded its US tax presence on April 2 2004 with the hire of Daniel Kraus for its Chicago office. Kraus, formerly a partner at Schiff Hardin, concentrates his practice in flow-through entity taxation, taxation of real estate investments, affordable housing and community development, start-up and growth-oriented investments, tax controversy, and tax litigation.
  • Member states need to respond to ECJ decisions in an holistic way, says Philip Gillett, group taxation controller of ICI, in an interview with International Tax Review