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  • Richard Collier-Keywood was elected head of PricewaterhouseCoopers' UK tax practice on November 4 2003. Collier-Keywood was responsible for business development and marketing and has led the UK direct tax practice since entering the partnership in 1992.
  • On November 6 2003, the United States and Japan signed a new income tax treaty and a protocol to the new treaty, and exchanged diplomatic notes concerning the interpretation of certain provisions of the treaty and protocol. The US Senate and the Japanese Diet should take up the treaty early in 2004, and ratification appears highly likely. If ratified, the new treaty will replace the existing treaty, which was entered into in1971.
  • In late October 2003, Germany's highest tax court (the Bundesfinanzhof or Federal Tax Court) released a judgment holding that corporate net operating losses (NOL) continue to be deductible following indirect changes in the ownership of the loss corporation (judgment of August 20 2003 - IR 61/03). For prior discussion of the case and related NOL disallowance issues, see the article by Prinz zu Hohenlohe and Gruendig in International Tax Review (May 2003, page 25).
  • Sed Crest reveals what kind of picture the survey of tax services in Latin America draws and presents the challenges for tax directors and warnings for tax advisers
  • 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. Certain major changes, and a host of technical revisions, have been adopted. The FIE legislation is to be effective for taxation years beginning after 2002.
  • Argentina has recently launched new thin-capitalization rules by reforming the Income Tax Law, effective October 22 2003.
  • Dennis G Dimagiba and Jehremiah C Asis of Quisumbing Torres (associated office of Baker & McKenzie) explain how to structure swaps, repurchase and stock lending agreements
  • Stephan Baumann of Deloitte & Touche warns that even though Switzerland's lump-sum tax credit system may relieve the burden of double taxation, the complex procedures demand a cautious approach
  • On December 11 2003 the Mexican Congress began debating controversial reforms to gradually reduce corporate taxes to 30% by 2006. There were angry demonstrations over plans to slap an 8% tax on all goods that are now exempt from taxation, including food and medicine.
  • Marks & Spencer's head of tax, Philip Martin explains his uncanny affection