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Sean Foley Landon McGrew The IRS and Treasury department recently released final regulations (TD 9452) addressing the application of separate foreign tax credit limitations to dividends received from 10/50 corporations.

Henry An David Jin-Young Lee The National Tax Service (NTS) released tax audit guidelines for 2009 in September. These guidelines provide details on the criteria used to select companies for regular tax audit for 2009. The guidelines were developed in consultation with the Audit Selection Review Committee and the Advisory Committee for National Tax Administration. The announcement is intended to enhance transparency and predictability for taxpayers.

Edward Tanenbaum The affordable Health Choices Act of 2009 (HR 3200), promotes health care reform. Among the revenue provisions of the Act is one to restrict, in certain cases, the use of tax-treaty benefits by foreign firms with operations in the US. The proposal would amend section 894 of the Internal Revenue Code (code) relating to income affected by a treaty.

Cenk Ulu Ezgi Yorulmaz Value added tax (VAT), customs duties and special consumption tax (SCT) represent a major source of revenue for Turkey. Approximately 70% of the total tax revenue is collected through indirect taxes. It is obvious that the Turkish state mainly depends on indirect taxes.

David Cuellar Araceli Sosa On August 13 2009 Colombia and Mexico signed an income tax treaty with the purposes of mitigating tax burden, preventing double taxation and boosting the economic welfare of both countries. The treaty will enter into force after the exchange of the instruments of ratification.

Vladimir Kotenko On August 26 2009 the cabinet of ministers passed resolution no. 895 attempting to restrict tax deductibility of foreign currency exchange losses. Specifically, taxpayers were strongly discouraged from deducting unrealised currency exchange losses resulting from revaluation of loans and some other foreign currency liabilities. The resolution blatantly contradicted the CPT Law.

Sophie Stylianou For companies active in the development and licensing of intellectual property (IP) rights, efficient ownership structuring is vital. The direction of the relevant licence payment is also important so as to make transactions as tax efficient as possible.

Janne Juusela The Finnish tax system has been amended regarding the payment of most indirect taxes. These include VAT, income tax deducted at source, employers' social security contribution, withholding tax, insurance premium tax, and lottery tax.

Advocate general (AG) Paulo Mengozzi has said that certain aspects of the UK's stamp duty reserve tax (SDRT) breach EU law. In his opinion, SDRT breaches the capital duty directive and the EC principle of the free movement of capital.

The Obama administration is setting up a review group ahead of what has been described as a "major overhaul" of the Internal Revenue Code in 2010.