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  • International arbitrators working in Singapore will no longer be subject to withholding tax of 24.5%
  • Efforts are made to phase out the extraterritorial income exclusion regime, anti-inversion legislation is proposed, and broad business purpose/economic substance standards are set. By Hal Hicks, David Benson and Margaret O’Connor of Ernst & Young, Washington DC
  • US firm Oppenheimer Wolff & Donnelly has hired a KPMG tax partner to lead its tax group in France. Kelly Williams joined the firm's Paris office in early April having been at KPMG since 1994. She previously worked at Andersen in Paris and is trained as both a lawyer and an accountant. Oppenheimer contacted Williams in October last year and has since hired a tax associate for the Paris group. The firm has six partners in Paris, as well as European offices in Brussels and Geneva, and, according to Williams, is planning further expansion across all practice areas throughout Europe. Williams decided to leave KPMG because she was unhappy with the type of work she was performing as a tax partner at a big five firm. She commented: ?Over the years the hierarchy in the big five firms has become oppressive. Once you become a partner there is a lot of administrative work, selling and delegating. I don't think that contributes to serving clients.?
  • Covering foreign employees in US retirement plans is a complex area and mistakes can be costly. Robert H Masnik and Karen Field of KPMG’s Washington National Tax Compensation and Benefits practice discuss the issues
  • The US has failed to recognize the European Union as a single economic entity for tax purposes. This raises a number of potential problems for US and EU companies. By Stephen E Fiamma and Dave Lewis of Allen & Overy's US Tax Group, London
  • Canada’s revenue authorities are taking an aggressive stance on profit split methods – taxpayers use them at their peril. By Hendrik Swaneveld, Venkat Nagarajan and Martin Przysuski, BDO Dunwoody LLP, Toronto (Markham)
  • A tax appeal tribunal in the UK has ruled that a transfer pricing adjustment to income may be made to companies that set up and support share option schemes for employees of foreign subsidiaries. The Special Commissioners (the first level appeal tribunal on tax cases in the UK) held that share options provided on behalf of foreign subsidiaries were a business facility provided by the UK company to the foreign subsidiaries.
  • Tax authorities in a number of countries are increasingly focusing on transfer pricing issues related to stock options. Ernst & Young transfer pricing and stock-based compensation professionals have collaborated to review the pitfalls and opportunities with particular reference to the UK, the US and Germany. By Gareth Green and Jeremy Glover in London and Stanley Veliotis in New York
  • Nearly two years after the OECD first published its list of 35 uncooperative tax havens, the Paris-based organization has finally issued its revised blacklist and has, for the first time, made clear that any defensive measures could hit uncooperative OECD members and non-members alike. With only seven countries still on the list, the US is claiming credit for much of the project's success, stating that it was only due to their insistence on changing the direction of the project that most countries signed up.
  • London-based law firm Lovells has launched a Dutch practice in Amsterdam with the appointment of a team of three lawyers, led by Anton Louwinger, formerly of Andersen in Rotterdam. Louwinger will become a tax partner as soon as the necessary professional formalities are in place. Louwinger will be joined by Aart Nolten and Christiaan van Waalwijk van Doorn, both of whom also come from Andersen's Rotterdam office. Prior to working at Andersen, Louwinger worked with Loeff Claeys Verbeke and Van Mens & Wisselink, whose Rotterdam office he helped to set up.