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Taxpayers who believe that their transactions are too complex for the revenue authorities to sort out should pay very close attention to recent IRS victories in the US courts. By Keith Martin, Chadbourne & Parke, Washington DC

A recent ruling means that non-resident companies with a permanent establishment in India must now comply with the country’s minimum alternative tax policy. Jignesh R Shah, Price Waterhouse & Co, Mumbai analyzes the case and its implications

New York-based tax litigator Lawrence Hill has joined White and Case as a partner. Previously, he was head of tax litigation and Internal Revenue Service controversy at Brown & Wood. Hill plays an active role as an advocate for the accounting profession and represents a number of big five firms. Specialities include advising accountants on ethical and risk management issues. He has also represented banking and investment banking companies in tax and litigation matters.

Self-assessment for transfer pricing exposes taxpayers to several potential risks. In this context an effective APA system is vital. Robert Cole, Alston & Bird, Washington DC and Michael McGowan of Allen & Overy, London outline their recommendations.

Lockheed Martin, the US defence and aerospace group is to acquire satellite communications company Comsat for $2.7 billion. The deal will require US Congressional approval, because under US law, no company is allowed to hold a stake exceeding 49% in Comsat, a former monopoly. Lockheed is advised by US law firm King & Spalding. Tax advice came from partners Thomas Wessel in Washington DC and Robert Woodward in Atlanta.

First Active, the Irish building society, is to be floated on the London and Dublin stock exchanges. The market capitalization is expected to reach IR£510 million ($710 million). First Active is raising IR£104 million new capital to fund expansion. The building society has operations in Ireland, Northern Ireland, the UK and Guernsey. Arthur Andersen in Dublin provided tax advice on the Irish aspects of the flotation. The tax partner involved was Sharon Burke. Tax managers were Maireod Foley and Frank O'Neill. Advice in Dublin also came from PricewaterhouseCoopers and law firm Arthur Cox.

At long last, after months of promises and delays from the government, and considerable nail biting from the tax community, the UK Inland Revenue has produced a consultative document on a general anti-avoidance rule (GAAR). The possibility of a UK GAAR was first suggested by chancellor Gordon Brown in 1997, but the new document is the first concrete proof that the government intends to act on the idea.

Directive 69/335/EEC — Taxes on the raising of capital — Tax on companies’ net assets.

Directive 69/335/EEC — Indirect taxes on the raising of capital — Merger of companies — Acquisition by a company which already holds all the securities of the companies acquired.

Directive 69/335/EEC — Indirect taxes on the raising of capital — Duty on notarial deeds recording the repayment of debenture loans.