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In 1999, Congress directed the Internal Revenue Service (IRS) to conduct a study of compliance with the documentation requirements of Internal Revenue Code (IRC) section 6662. The IRS recently released a report detailing its findings.

The draft amendments to the Tax Code have passed two readings in the State Duma (the lower chamber of the Russian parliament). The amendments include a broad list of changes in taxation, most of which are technical in nature and intended to eliminate ambiguities in recently introduced chapters of the Tax Code. Nonetheless, some of the proposed amendments may have a substantial impact on the taxation of foreign investors in Russia. The most important amendments are summarized below.

The Spanish government has initiated a process to partially reform personal income tax by commissioning a committee of experts, chaired by Professor Manuel Lagares, to prepare a report on the fundamental aspects of the tax and then draft a bill. The bill has been sent to the Spanish lower house.

As a consequence of the 2002 comprehensive Mexican tax reform approved by Congress, the Mexican Income Tax Law now considers that when a Mexican tax resident entity ceases to be a Mexican resident under the rules established in the Mexican Federal Tax Code (ie when it changes its tax residence to a country other than Mexico), it will be deemed to be liquidated for Mexican tax purposes. The purpose of this change is to avoid the transfer of Mexican taxable income to a foreign country, as such a transaction is detrimental to the Mexican Treasury Department.

Cross-border reorganizations rank among the most complex tax planning transactions. Two recent changes in German tax law open up new possibilities for accomplishing certain cross-border reorganizations without realization of gain.

UK Inland Revenue may seek to recover tax credits from non-resident shareholders

Sluggish US investment in new plant and equipment gets a boost from a new depreciation bonus offering a 30% tax discount. Keith Martin of Chadbourne & Parke LLP, Washington looks in detail at how it works

Canada announced that its new transfer pricing rules would simplify the APA process for companies. Unfortunately, this is certainly not the case. Hendrik Swaneveld, Martin Przysuski and Venkat Nagarajan of BDO Dunwoody, Toronto (Markham), report

Singapore’s budget aims to encourage economic progress at a time of political uncertainty and intense competition. Taxation targets enterprise and growth, while attracting global talent. By Ajit Prabhu, Deloitte & Touche, Singapore

The recent UK budget announced changes that will make corporate compliance more complex. Simplicity and fairness may be the aim, but achieving it is going to require more hard work for practitioners. Derek Jenkins, PricewaterhouseCoopers, London