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  • Watson Farley promotes tax lawyer to top spot, Herkenroth swaps Andersen for Ashursts, Casino owners hit tax jackpot, Accountancy nerds knocked off blackspot, Driver eats evidence of unpalatable crime, Savory takes the softer option, Experience available: any takers?
  • Two former colleagues from Baker & McKenzie will find themselves competing for business after being recruited into big five firms. Phil Morrison, a tax partner from Baker & McKenzie in Washington, has joined Deloitte & Touche as leader of the International Tax Group of the Washington National Tax Practice.
  • US firm Cleary Gottlieb Steen & Hamilton is advising HSBC on its acquisition of Republic New York and Safra Republic. Safra Republic is the Luxembourg holding company for Republic's European operations. The acquisition is valued at $10.3 billion and will give HSBC the third-largest branch network in New York as well as a large base of private clients.
  • Brobeck Phleger & Harrison advised Rhythms NetConnections Inc, a US Internet connection provider, on its offerings of shares and debt.
  • Until recently, Ireland would not have been considered a favourable location for a holding company. This was because relatively high rates of tax were imposed on dividend income and capital gains, and because credit relief for foreign taxes suffered was quite limited. Since the enactment of its new corporate tax regime, a reduction in the rate of capital gains tax and amendments to the rules concerning credit relief for foreign taxes, however, the opportunities for using Ireland as a holding company location merits serious reconsideration by corporate treasurers when planning their international group structures.
  • Ireland risks the animosity of its EU partners by adopting a policy of low tax rates for trading companies. But does this make it a tax haven or just a fair competitor for international business? Rosie Murray-West talks to both sides in what promises to be a heated debate
  • A recently reported advance ruling has clarified the scope of the term 'technician', as contemplated by section 10(5B) of the Indian Income-tax Act, 1961. Section 10(5B) grants tax exemption to a foreign technician, in as much as the tax paid on his remuneration by his employer for a period not exceeding four years, (commencing from the date of his arrival in India) is exempt, subject to certain conditions. Technician has been defined to mean a person having specialized knowledge or experience in construction, manufacturing or mining operations or generation of electricity or any other form of power or agriculture and allied activities or such other fields as are notified by the central government. To quote few instances - in Monte Harris, a person with experience in software development was accepted as a technician; in Arthur E. Newell, the act of perforation of films according to international standards was held to involve expertise, which would qualify the employee to be characterized as a technician; in David Kenneth White, a specialist who had expertise in telecommunication networks was accepted as a specialist on information technology.
  • At the time of introduction of the recent tax reform legislation (see International Tax Review April 1999), the German government also announced its intention to reduce the cumulative trade tax and income/corporation tax burden to approximately 35% for all businesses, whether operated as corporations, partnerships, or sole proprietorships, beginning in the year 2000.
  • Cyprus’ treaty network with eastern European jurisdictions has provided new opportunities for offshore tax planning. Constantinos Adamides of Adamos K. Adamides & Co examines the provisions and possibilities offered by the Cyprus-Russia treaty
  • Over the next two months, International Tax Review will publish a series of features examining CFC regimes around the world. Recent years have seen a rapid expansion of the scope of such regimes. Oliver Ralph reports on how multinationals are beginning to fight back