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  • The 2003 Finance Act created a favourable tax status for publicly quoted property investment companies in France. Philippe Royou of Simmons & Simmons believes the advantages of corporate tax exemption and a stock exchange listing may encourage other European countries to follow France's example
  • Giuliana Polacco of Baker & McKenzie explains when the new rules will apply and how to escape them
  • Australia finalized double taxation treaties with the UK and Russia on December 17 2003. The Australia-UK treaty will go into effect on 1 July. The Australia-Russia treaty became effective on 1 January 2004.
  • By Tim Brown and Joanna Klaentschi, tax investigations, PricewaterhouseCoopers in London
  • US law firm Greenberg Traurig added Richard Petkun to its tax practice in Denver on January 7 2004. Formerly of Isaacson Rosenbaum Woods & Levy, Petkun's practice focuses on international tax, transactional and real estate tax matters.
  • Foreign corporations that have US subsidiaries selling tangible personal property within the US may be familiar with the concept that the commerce clause of the US Constitution, which serves to limit state action to the extent that it burdens national commerce, prohibits a state from requiring sellers who have no physical presence or a de minimus presence within the state (known as remote sellers) to collect sales tax on purchases of goods shipped to in-state customers.
  • Spain has put a favourable tax regime in place for foreign employees assigned to the country, effective January 1 2004. Individuals that transfer their tax residence to Spain can opt between being subject to personal income tax as Spanish residents and being treated as non-residents, provided that they meet certain requirements:
  • Ted Keen: Pharmaceutical caompanies should use APA process GlaxoSmithKline (GSK), the world's second-largest pharmaceutical company, has rejected a claim from the US Internal Revenue Service (IRS) that the group owes $2.7 billion in back taxes and $2.5 billion in interest.
  • UK magic-circle law firm Allen & Overy (A&O) has taken over a top Italian tax boutique to boost its European tax practice in Milan and Rome. Andrea Manganelli and Francesco Parisi, co-founders of Andrea Manganelli e Associati, joined A&O as partners on January 29 2004 and brought 15 tax associates with them. A&O also hired Quirino Imbimbo as of counsel in the Milan office.
  • 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.