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  • Section 155A of the French Tax Code (FTC) aims to prevent taxpayers domiciled or established in France or abroad from taking shelter under foreign service companies in order to avoid tax on amounts that would in principle be taxable in France.
  • Where an Australian consolidated group is owned by a foreign parent company, consideration must be given to the tax impact for the foreign parent of how the liability to pay the Australian group's income tax arises.
  • 1. Corporate tax compliance
  • A joint Bill proposed by a Republican and a Democrat Congressman sets out to extend the ban on new and discriminatory taxes on the internet indefinitely. Senator Ron Wyden and Representative Christopher Cox introduced the Bill, which would permanently extend their internet tax non-discrimination act due to expire this November.
  • Texas-based Fulbright & Jaworski has announced the election of Stephen Pfeiffer as its new chairman. Pfeiffer was previously partner-in-charge of both the Washington DC and London offices, and head of the firm's international department. Pfeiffer replaces Gus Blackshear, who has served 10 years as chairman and will return to practising law as a tax partner in Fulbright's Houston office.
  • Professional services firm Ernst & Young has hired a former director, Matthew Taylor from KPMG to join its tax group. Taylor is joining as a tax partner on March 24 2003. Taylor has been actively involved in insurance demutualizations and mergers. He has been a director with KPMG since 1996.
  • Jones Day Reavis & Pogue in Paris has hired a tax and real estate partner from HSD Ernst & Young. Emmanuel Chauve is joining the firm in early February from the merged Ernst & Young and Andersen Legal team, which has lost teams to firms including Deloitte & Touche, Bird & Bird, Willkie Farr & Gallagher and Baker & McKenzie since its September union.
  • Julian Robertson-Kellie has joined Ernst & Young in London as a director in the international transfer pricing and tax-effective supply chain management group. Robertson-Kellie was previously working in Zurich and was responsible for the company's European transfer pricing issues for more than four years.
  • KPMG has hired Sean Foley, former director of the US Internal Revenue Service's (IRS) advanced pricing agreement (APA) programme. Foley will split his time between New York and Washington.
  • The US firm has boosted its tax group with a former principal from KPMG. David Wunder has joined the firm as a partner and will be splitting his time between the firm's Detroit and Washington DC offices. Wunder claimed that the Sarbanes Oxley legislation would prevent him from working with his biggest clients, including Wells Fargo.