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Sed Crest speaks to the leading tax advisers in North America at a time when creative tax advice is under increasing threat from the media, lawmakers and the IRS

The Supreme Court agrees to review the Boeing decision, a new information agreement is signed with Netherlands Antilles, and the IRS denies APAs to check-the-box taxpayers. By Hal Hicks, David Benson and Peg O'Conner, Ernst & Young, Washington

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Canadian firm Torys has hired two tax partners and an associate from the defunct Andersen for its New York office. Gary Gartner and Jeffrey Scheine have joined the firm as partners while Pamela Petree has joined as an associate; all join from Andersen's New York office. Gartner was previously the head of Andersen's international tax practice in New York with responsibility for the northeast region of the US and Canada. He focuses on US federal income tax law affecting both foreign and domestic taxpayers with particular experience in US-Canada cross-border work. Scheine was previously in the transaction advisory services (M&A) group at Andersen while Petree had been working as an international tax manager at Andersen for five years.

Freshfields Bruckhaus Deringer has lost its head of Dutch tax to a local firm. Charles Langereis joined Spigthoff on July 1 and will lead the firm's tax practice. Before working at Freshfields Bruckhaus Deringer he headed the tax group at Stibbe. He brought over one associate and many of his clients.

On July 12, the IRS released revenue procedure 2002-52, updating the procedures for requests for competent authority assistance. Revenue procedure 2002-52 supersedes revenue procedures 96-13 and 96-14, the prior IRS guidance on this subject.

Spanish tax law provides for a 3:1 debt-to-equity ratio for the net interest-bearing indebtedness of Spanish companies towards non-resident related parties. Interest accrued on any indebtedness that exceeds this ratio is considered as a dividend for tax purposes. The ratio does not apply to financial entities.

India's Finance Act 2001 introduced transfer pricing provisions. Tax payers are now gaining their first experiences of how to comply with the new rules. By Samir S Mogul, S I Mogul & Co, Mumbai