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Lawrence Kemm joined McDermott, Will & Emery in the UK from Baker & McKenzie on June 16 2003. Kemm is confident that McDermott, Will & Emery's relationship with other firms around the world will allow him to continue providing high quality tax advice internationally.

Michael Weaver and Travis Taylor, formerly in PricewaterhouseCoopers's tax valuations department, have set up Gravitas Partners in the UK with two former colleagues from the big-four firm. The practice hopes to provide a more personal service to its clients (some of whom have followed Taylor and Weaver from PricewaterhouseCoopers), while also providing access to senior tax practitioners with experience in a big-four firm.

Eric Roose: Avoiding high local taxation is important for offshore funds White & Case has launched a Tokyo investment and hedge-fund desk with its associated firm Kandabashi Law. The new eight-strong group delivers advice to offshore fund managers regarding tax-efficient hedge-fund structuring. Chris Wells, executive partner of White & Case in Tokyo, leads the group. Eric Roose and Yoshiaki Uno are also partners working on the project.

by Guy Brannan, Head of Tax, Linklaters

The January 2003 issue of International Tax Review reported on the landmark Lankhorst-Hohorst decision of the European Court of Justice (ECJ Case C324/00 of December 12 2002) by which the court held a central provision of the German thin-capitalization rules to contravene EU law.

The Canada Customs and Revenue Agency (CCRA) continues to provide favourable advance income-tax rulings for a common but attractive cross-border financing structure. The structure is used for the financing of a Canadian subsidiary by its US parent. It provides for a tax deduction in Canada and no immediate income inclusion in the US. It also results in a so-called double-dip if the US parent has borrowed the money used to finance the Canadian subsidiary, in particular a deduction of interest expense in both Canada and the United States.

New M&A rules, which became effective on April 12 2003, allow the involvement of foreign investors in domestic M&As for the first time. The new rules allow for acquisition of equity where the foreign investor purchases the equity of a domestic enterprise by agreement or subscription to the increased capital of the domestic enterprise, thereby transforming the domestic enterprise into a foreign invested enterprise (FIE); and acquisition of assets where a foreign investor sets up a FIE, and then purchases and operates the assets of a domestic enterprise or purchases the assets and uses them as investment in a newly established FIE.

Roberto Haddad of Branco Consultores explains what the tax reforms will mean for companies operating in the country

Type of deal

Japan's influential government tax commission set out wide-ranging plans for the future of Japan's tax policy on June 17 2003. The proposals include suggestions related to individual income tax, the taxation of pension benefits, consumption tax, corporation tax and excise duties. Prime Minister Junichiro Koizumi is under intense pressure to raise taxes to fill the hole in government finances, but there is fear that this could stifle the already sickly economy. The government cut corporate taxes earlier this year in an effort to stimulate activity.