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  • 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.
  • PricewaterhouseCoopers announced the appointment of Stephen Camm as head of its UK tax investigations practice on January 28 2004
  • In an effort to increase the transparency of corporate tax return filings, the US Treasury and IRS on January 28 2004 released a new proposed draft form for use by certain corporate taxpayers. The new form affects corporations with total assets of $10 million or more and will help the IRS improve monitoring of corporate tax compliance.
  • 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
  • The law for setting up National Tax Tribunals (NTT) was promulgated recently to dispose of tax cases faster
  • The proposed section 482 services regulations change many aspects of the transfer pricing regulations for related-party services and the ownership of intangible property