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  • 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.
  • 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.