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Clifford Chance has chosen Douglas French for its new global practice area leader for the tax, pensions and employment practice

The US Treasury has released regulations it plans to use to stop groups of companies from duplicating losses for tax purposes

Following the publication of Normative Instruction 167 (June 18 2002), the Brazilian tax authorities issued, on October 1 2002, Normative Instruction 200 (NI 200), which brings further details and clarification about the new requirements for legal foreign entity domiciled outside Brazil to obtain a taxpayer identification number. Under NI 200, non-resident companies owning goods and rights in Brazil, subject to public registration, are obliged to apply for and obtain a federal taxpayer identification number. This is known as the Cadastro Nacional da Pessoa Jurídica (CNPJ).

The US accounting profession has announced a new standard for detecting fraud in company audits. The Auditing Standards Board of the American Institute of Certified Public Accountants (AICPA) made the announcement on October 15 2002. The provisions include increased emphasis on professional scepticism, discussions with management about the risk of fraud, unpredictable audit tests and testing for management override of controls on audits.

New corporate restructuring rules mean companies need to look carefully at how they use losses and those of potential acquisition targets. For the nimble, Marcellin N Mbwa-Mboma, of Baker & McKenzie in New York, says the advantages can be significant

Ernst & Young failed to suspend a disciplinary investigation into its audit of insurance company Equitable Life. The High Court overruled Ernst & Young's claim that an inquiry would compromise its position in civil proceedings brought against it by Equitable. Ernst & Young has staunchly defended its 1999 audit of Equitable that led to the company suing the professional services firm as well as company directors on behalf of its policy holders.

Germany's controlled foreign corporation (CFC) rules (section 7 ff AStG - Außensteuergesetz or International Transactions Tax Act) treat the passive earnings of foreign corporations in low-tax jurisdictions as distributed to German resident taxpayers (immediate deemed distribution) if German residents have a direct or indirect interest of more than 50% in the foreign corporation. Low-tax jurisdictions are those with an effective tax rate under 30% through fiscal year 2000 and under 25% from fiscal year 2001 onwards.

Many banks and companies are now engaged in debt restructuring negotiations but are unaware of the minefield through which they walk. Heléna Klumpp of Chadbourne & Parke LLP, Washington looks at the tax issues involved and suggests ways to plot a course

The IRS has issued its final QI audit guidelines. Now the first QI audit is approaching. It will be a landmark for financial institutions and auditors and will test the practicality and efficiency of the QI withholding system. Chip K Collins, KPMG, Washington DC, and Hans-Dieter Wolf, KPMG, Düsseldorf report

Pamela Olson has been sworn-in as US treasury assistant for tax policy. Treasury secretary Paul O'Neill swore-in Olson on September 26 this year. Olson has supervisory responsibility for providing the treasury secretary with policy analysis, advice and recommendations relating to all aspects of domestic and international issues of federal taxation including legislative proposals, regulatory guidance and tax treaties. She will also deal with official estimates of government receipts for the president's budget, fiscal policy decisions and treasury cash management decisions.