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Japan’s new domestic special company will ease liquidation and securitization for domestic and foreign corporations. But as Dean Yoost and Sachihiko Fujimoto of PricewaterhouseCoopers in Tokyo argue, its stringent requirements mean other vehicles retain an appeal

New directives and a number of recent cases have brought the conclusions of the 1992 Bachmann case into question. Hans van den Hurk of PricewaterhouseCoopers, Eindhoven examines the consequences for insurance taxation in the Netherlands

The Austrian government has put forward draft legislation setting out a Sch32.5 billion ($2.5 billion) package of tax cuts.

The Canadian Department of Finance has proposed transitional tax rules for foreign banks that wish to convert from a subsidiary to a full-service branch.

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

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.