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  • Paul, Hastings, Janofsky & Walker has expanded its international tax practice with the hire on February 26 2004 of Mark Lange from McKenna, Long & Aldridge. Lange's practice focuses on transactional tax issues involving domestic and international mergers, acquisitions, partnerships, joint ventures, alliances, limited liability companies and other pass-through and venture capital entity transactions.
  • James Malone, formerly president and general counsel at New Power Holdings, has joined Winston & Strawn. Malone, formerly a senior partner at McDermott, Will & Emery and chairman of its tax controversy practice, began working as a tax partner at the firm's New York and Chicago offices on February 12 2004.
  • Ceteris, the transfer pricing boutique, has hired another transfer pricing economist from Ernst & Young in the US. David Reichow joined the firm as a vice president on March 22 2004. Reichow joins former Ernst & Young colleagues Sherif Assef and Michael Heimert. Heimert set up Ceteris in August 2003 to provide an alternative to the big four accounting firms' transfer pricing practices.
  • Philip Martin: wants to roll his sleeves up Philip Martin, deputy head of tax at UK retail group Marks & Spencer, left the company to join Dorsey & Whitney's growing litigation team in London in February 2004.
  • The big-four accounting firm KPMG has continued the restructuring of its international tax practice with the appointment of a new head of tax for Europe, Middle East and Africa, its largest operating region. Loughlin Hickey, head of tax for KPMG in the UK, was appointed to the role on March 3 2004.
  • UK retailer Marks & Spencer will appoint Eileen Haughey, now a partner with Deloitte & Touche in London, as its new head of tax on June 1 2004.
  • It is common in the US to acquire companies in tax-free stock acquisitions. These are referred to as tax-free reorganizations and they must qualify for tax-free treatment under section 368(a) of the Internal Revenue Code. Section 368(a) provides detailed requirements for several different types of reorganizations (mergers, triangular mergers, stock-for-stock exchanges, spin-offs and certain types of stock-for-asset exchanges for example).
  • The Spanish CIT law has been reformed for tax years commencing on 2004, to further improve the tax credits for research and development (R&D) and innovation activities.
  • The increasing complexity and range of tax rules affecting international business require sophisticated and dynamic tax infrastructures in order to deliver global tax objectives. It is for this reason that Ireland is a particularly attractive location for multinationals.
  • The Japanese Diet is expected to ratify the new treaty by the end of March 2004, allowing the treaty to become effective on January 1 2005 in general, except for the provisions relating to withholding tax on dividends, interest, and royalties, which will become effective on July 1 2004. In order to adequately conform to the new treaty, Japan must pass new domestic tax rules as follows.