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In what many view as a rather surprising decision, Canada's Federal Court of Appeals (FCA) recently ruled that a US consultant did not have a fixed base (ie taxable presence) in Canada. Under article 14 of the Canada-US treaty, and any other OECD-based treaty, a host country does not tax an independent contractor unless he or she works from a fixed base. The same guidelines determine whether the presence of a US company's employees in Canada creates a permanent establishment, which is defined as a fixed place of business through which the business of an enterprise is wholly or partly carried on.

The biggest surprise in the UK’s 2000 budget came in the form of the abolition of offshore mixers. This is just one aspect of a toughening of the Inland Revenue’s stance across the board. Helen Lethaby and Susan Bell of Freshfields, London outline the aggressive new regime

A call to PricewaterhouseCooper's office in Singapore reveals the true breadth of the firm's client services. Having phoned PwC's listed number, International Tax Review was intrigued to discover that it had reached White Express, a downtown laundry service.

The classic concept of a Swiss finance branch has been experiencing an impressive revival. Stefan Widmer and Matthias Blom of Arthur Andersen, Zurich advise on how to expand the concept to a wide range of treasury functions and adapt it to a group's intangible properties

The Canadian government has cherrypicked from the Mintz Report to introduce a series of reforms to Canada's thin capitalization rules. Elinore Richardson of Stikeman Elliott, Montreal, outlines the changes and reviews the rationale behind them

India has backtracked on threats to end capital gains exemptions for foreign institutional investors.

Sullivan & Cromwell provided tax advice through tax partner Andy Mason, and associates David Spitzer and Mike Foley. Alan Kaden, lead tax partner with Fried, Frank, Harris Shriver & Jacobson's Washington office provided tax advice for BellSouth.

Sullivan & Cromwell in New York is working on the deal for Dexia. Tax partner Andy Solomon and tax special counsel Rich Alpern were assisted by associates Rebecca Coccaro, Ted Markson and David Spitzer. Michael Schler of Cravath, Swaine & Moore is advising FSA Holdings.

As a result of the deal, UK investors will have access to CREST settlement of US shares in the S&P 500 and the NASDAQ 100 indices. Davis Polk & Wardwell advised CREST. Jordan Luke of the Washington DC office, Randall Guynn of the New York office and Margaret Tahyar of the London office worked on the deal.

Singapore's minister for finance presented the 2000 budget proposals to Parliament on February 25 2000.