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Argentina has one of Latin America's oldest and most established tax treaty networks. These treaties play a key role in the optimization of global structures involving an Argentine business presence.

The Isle of Man has put forward proposals aimed at revamping its existing regime and building on its success as an attractive business location

The US Treasury has published its final regulations denying US treaty benefits to payments made through so-called hybrid entities. The regulations’ limited scope means they only deny treaty benefits that might otherwise be available. By Kim Blanchard of Torys, New York

The American Bar Association (ABA) has voted overwhelmingly to reject multidisciplinary practices (MDPs), and in so doing has dismayed the accounting industry.

Heikki Haapaniemi

Wading into one of the most controversial policy debates of the new economy, the California legislature voted Wednesday to force many internet retailers to charge sales tax in California. At a time when government leaders from Washington to Wyoming are eyeing substantial tax revenues from the rapidly expanding e-commerce business, the Assembly's 42-to-31 approval of a measure by Carole Migden, D-San Francisco, thrusts California to the forefront of the debate.

International telecommunications company Cable & Wireless Communications plc and Cable & Wireless independent directors have restructured in a transaction worth £17.1 billion ($25.4 billion).

On June 30 2000, the US Treasury issued final regulations under section 894 regarding the availability of treaty benefits for US-source payments made to certain hybrid or fiscally transparent entities. Under the final regulations, a US-source payment to a fiscally transparent entity is generally not eligible for the reduced rate of withholding tax provided for under a treaty unless the payment is taken into account currently by a treaty country resident. The regulations only apply to US-source income that is not effectively connected with a US trade or business. The final regulations are effective for items of income paid on or after June 30 2000.

Pursuant to the Finance Bill 2000, the French tax authorities issued new guidelines (Inst. Adm. n°13 D 1 00, June 27 2000) commenting on the rules regarding the granting of rulings for tax-free spin-offs and split-offs (Apports partiels d'actifs and Scissions), as from January 1 2000. Under French tax law, it is possible to benefit from a tax deferral mechanism in the case of a demerger if certain conditions are met (among other things, the assets and liabilities contributed constitute a full and autonomous line of business; the company contributing the full and autonomous line of business undertakes to keep the shares received for three years; and commitments regarding the computation of future capital gains). When those conditions are not met, a ruling must be applied for to benefit from the regime. This is the case, for instance, when a foreign company contemplates contributing its French permanent establishment to a new French company.

The Singapore government aims to encourage hi-tech start-ups through its new Entrepreneurial Employee Stock Option Scheme. On offer is a 50% tax exemption, in addition to the already low corporate and personal income tax rates. By Linda Ng of White & Case LLP, Tokyo