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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.

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

Ernst & Young acquires compliance firm, Tax probe reveals JAL discrepancies, Colombia extends banking tax, Brazil offers concessions to states, Venezuela offers tax breaks to oil investors, Japan reforms stock and bond tax, Mexico's maquilas fear tax change

Carter Ledyard & Milburn are advising UK group United News & Media on their acquisition of CMP Media, the US media group. United will add the Internet and print publishing businesses of CMP to its interests in PR Newswire and the UK's Channel 5 and other TV companies. The deal is worth $920 million. United News will pay $39 for each CMP share.

The Paris Office of Jones Day Reavis & Pogue is acting for Renault on their merger with Japanese company Nissan. The merger, which is valued at $5.4 billion, will create the fourth-biggest car maker in the world.

Ernst & Young in the UK and France is advising French minerals extraction and processing plant Imetal on its acquisition of English China Clays. The deal is worth £756 million ($1.2 billion).

Baker & McKenzie in New York and Stockholm advised Ford on its acquisition of Volvo's car division. The deal is valued at $6.45 billion.

Australia’s CFC regime has not escaped the recent review of business taxation. Alastair Macphee of Mallesons Stephen Jaques, Melbourne looks at the proposals and examines how group consolidation could cause problems for companies with CFCs

Brobeck Phleger & Harrison advised Rhythms NetConnections Inc, a US Internet connection provider, on its offerings of shares and debt.

The Internal Revenue Service (IRS) has announced its intention in Notice 99-25 to postpone the effective date of the withholding regulations under IRC § 1441 and related provisions. Those rules will now apply to payments made after December 31 2000. Although the extension is primarily in response to the difficulties faced by financial institutions, the extension delays the reporting requirement for treaty-based related party transactions. Unfortunately, it also means that distributing corporations may not elect to reduce the amount subject to withholding if the company has inadequate earnings and profits before January 1 2001.