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David Blumenthal: Will offer a broad tax practice Dewey Ballantine launched a UK tax practice after poaching London-based Linklaters tax specialist David Blumenthal on January 14 2004. The move highlights a growing trend as US law firms expand their tax practices to cater for their clients' UK and European tax advice needs.

Debate is growing in India on the attribution of profits to business process outsourcing entities (BPOs) that are permanent establishments (PE) of foreign companies in India. Under Indian tax treaties, a non-resident has a PE if it carries on business through a dependent agent in India. A dependent agent is an entity in India that exercises authority to conclude contracts or secures orders on behalf of the non-resident and is legally or economically dependent on the non-resident. Treaties say profits attributable to a PE are taxable in India. There are conflicting views on the extent of the profits attributable to the PE.

The American Bar Association (ABA) has said that the IRS must aggressively promote tax simplification to improve service to taxpayers and ensure that tax laws are effectively enforced

The Ministry of Finance announced the tax reform plan for 2004 on December 19 2003. The emphasis is on taxing individuals. Corporation tax has not been drastically changed but notable changes are as follows.

More than a dozen Bills aiming to reform Germany's labour market, public health insurance system, and tax laws were enacted in December 2003.

On October 31 2003 the Brazilian government issued Provisional Measure 135/2003, which, among other things, altered the rules for the application of the social security financing (COFINS) tax. It also introduced new provisions with respect to capital gains realized on the sale of Brazilian assets (including the shares of Brazilian companies) between Brazilian non-residents.

Gary Wilcox, deputy chief counsel (technical) for the US IRS will leave his post to return to private practice in mid-February. Wilcox has primary responsibility for the IRS's positions on technical tax issues and for issuing regulations and rulings. He will rejoin his former firm Morgan Lewis.

Ecuador’s Supreme Court has ruled that the Canadian oil company EnCana has the right to a partial rebate in its lengthy battle over tax rights with the government, but refuted the company’s claims for a full refund

The government of Nigeria has accused Shell of unfairly exploiting tax loopholes and could be forced to hand back hundreds of millions of dollars to the authorities. The tax dispute relates to a reserves-addition bonus scheme that offered companies incentives for investing in oil and gas.

The fourth draft of the foreign investment entity legislation (FIE legislation) was released by the Canadian Department of Finance on October 30 2003 and generally adheres to the structure of earlier drafts