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  • In a busy year, the US tax courts ruled on subjects ranging from foreign tax credits to related party borrowings. Daniel Berman and Jeffrey Korenblatt, Sutherland Asbill & Brennan LLP, Washington DC analyze the rulings and their consequences
  • Freedom of establishment – Establishment of a branch by a company not carrying on any actual business – Circumvention of national law – Refusal to register.
  • New York law firm Wachtell, Lipton, Rosen & Katz is advising USA Networks Inc, the cable shopping channel, on its acquisition of the internet search engine Lycos.
  • The UK Inland Revenue has published its revised regulations governing the payment on account regime that is introduced under corporation tax self assessment (CTSA). The revised regulations make few changes to the draft that was published in April 1998. The main changes are outlined below.
  • The period for offsetting tax loss carryforwards, which was increased in 1996 from five to seven years, has been further increased to 10 years with effect from January 1 1999.
  • The launch of the euro and, with it, European Monetary Union in Germany and the 10 other participating EU countries, effective January 1 1999, is the most significant European economic and political act since the founding of the European Economic Community in 1957.
  • Australian APAs are becoming an increasingly popular tool. But, as John Donaldson of KPMG in Melbourne explains, the Australian Tax Office still has some work to do to convince taxpayers that the process is secret and speedy enough to merit serious consideration
  • A recent circular from Vietnam’s Ministry of Finance has introduced extensive regulations for foreign investment. Tony Foster of Freshfields in Hanoi examines the consequences for multinationals who must now adopt Vietnamese accounting principles
  • In the first of our series of articles on advance pricing agreements around the world, Monique van Herksen of Stibbe Simont Monahan Duhot analyzes how the Netherlands APA system offers a new element in the traditionally strong Dutch advance rulings procedure
  • They’ve done it again. Less than two years after recruiting Robert Couzin from Stikeman, Elliott, the Canadian office of Ernst & Young has swiped another leading tax partner from a law firm. This time the partner in question is Ron Sirkis who until this month was head of tax at Bennett Jones Verchere.