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Kent Jones, a tax assistant to the solicitor general in the US Department of Justice since 1990, joined Sutherland Asbill & Brennan on March 16 2004. Jones, who specializes in tax litigation, joined the firm's Washington, DC office as a partner.

Donald Korb: vows to continue the struggle against tax shelters The US Senate Committee on Finance considered on March 8 2004 the nomination of Donald Korb, President Bush's choice for the position of IRS chief counsel.

Switzerland's new Customs legislation closely resembles EU regulations. Businesses can benefit from a detailed knowledge of it, say Heinz-Peter Karl and Michaela Merz of PricewaterhouseCoopers

The European Court of Justice ruled on March 11 2004 that the French legislation taxing unrealized capital gains simply because a taxpayer moves to another EU member state infringes the freedom of establishment (case C-9/02 Hughes de Lasteyrie du Saillant).

Belgium and Hong Kong's double taxation agreement offers a number of chances for tax planning. And, under certain conditions, withholding tax on dividends will not be levied, explain Kurt De Haen, Kris Vanderstappen and Guy Ellis of PricewaterhouseCoopers

Vladimir Putin, Russian President, has targeted the oil industry to pay for sweeping tax reforms that would cut social tax paid by Russian companies. He has said once the tax system is reformed, it must not undergo changes for a long time.

The US state of Michigan will give generous tax breaks to General Motors (GM) and Dr. Schneider Automotive Systems, a German car manufacturer, in a bid to retain and create manufacturing jobs. GM will get a $10.4 million single business tax credit over 20 years if it invests $299 million in its Warren transmission plant for future business while Dr. Schneider Automotive Systems will receive a $3.1 million tax credit over 15 years to build a new manufacturing plant.

Toronto

In the May 2002 issue of International Tax Review (page 58), we reported on a decision by the Cologne Tax Court interpreting language contained in article 23(3) of the former tax treaty between Germany and Canada as a subject-to-tax clause and giving this clause precedence over provisions in the treaty by which items of income "shall be taxable only" in Canada. On appeal, the Federal Tax Court (FTC) has now overruled both the lower court decision and its own 1992 holding on point (judgment of December 17 2003, IR 14/02).

On February 27 2004 the minister of finance released Revised Draft Legislation and Explanatory Notes (the new proposals) that contains significant changes to Canada's foreign affiliate regime. The new proposals revise draft legislation that was originally released on December 20 2002 (the 2002 proposals), and introduce a number of new measures (most not dealing with foreign affiliates), including measures to tax payments for non-compete covenants and measures to allow public corporations to return capital without generating a deemed dividend.