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Margie Rollingson, David Benson and Peg O'Connor of Ernst & Young analyze the Dow decision involving business purpose and corporate-owned life insurance where the court found in favour of the taxpayer

Proposed rules on preferred shares have a lot to offer foreign credit institutions in Spain. Carlos Albiñana of Allen & Overy shows where and how

For many years the Brazilian government has failed to enact fiscal reforms and to revise its inefficient indirect tax system, which imposes several types of taxes collected by the federal, state and local governments. Over the last decade this situation has developed into a serious tax competition between the different layers of the Brazilian government. The current tax system is characterized as a maze of complicated tax rules, which greatly increase the cost of products and services in the country. The result has been that Brazilian taxpayers are among those with the highest tax burden, representing 36.45% of the country's gross domestic product (only below Sweden - 47% and Germany - 36.7%).

Biotech company ImClone has delayed announcing its financial results and may be forced to restate its earnings from 2001 onwards to cover the unpaid taxes of its former chief executive.

The European Venture Capital Association (EVCA) has said that differences in national tax and legal regimes across Europe are hampering the development of Europe's private equity and venture capital sector.

Craig James - Integral Energy, Mark Tafft - Ernst & Young and Steve Vesperman - ATO:

Watson, Farley & Williams has hired a senior associate from Allen & Overy for its New York tax group. Patricia Iandoli has joined the firm's international tax group as a partner. Iandoli specializes in asset finance tax work.

Guernsey is recommending introducing a withholding tax on EU resident individuals' savings interest instead of exchanging banking information when the EU tax package and Savings Directive is adopted.

PricewaterhouseCoopers has hired Lindy Paull, the former chief of staff of the Congressional Joint Committee on Taxation as co-managing partner of its Washington national tax services practice. Paull joined the firm on May 1 2003 and will work with co-leader Robert Morris. Paull spent 17 years working in Congress, and before working at the Joint Committee on Taxation held positions with the Republican staff of the Senate Finance Committee.

The US Senate ratified the Protocol to the US-Australia double tax agreement (DTA) on March 13 2003. Overall, the Protocol to the treaty is good for business between the two nations and the outcomes are positive. Among other things, it gives Australian companies with US subsidiaries level pegging for dividends with the UK, the most competitive US tax treaty in the world.