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Bryan Bailey Jesse Brodlieb On December 15 2008, the 5th protocol to amend the Canada-US income tax treaty entered into force. The protocol contained a number of significant amendments to the treaty that affect the taxation of cross-border payments and eligibility of residents for treaty benefits. In particular, the protocol introduced a comprehensive limitation on benefits (LOB) rule applicable to US residents, as well as a rule which provides for the look-through of certain fiscally transparent entities (FTEs) (like US limited liability companies) when determining eligibility for treaty benefits. One practical difficulty arising from the protocol is how Canadian residents will know whether to apply treaty rates of withholding when making payments to US persons (including FTEs) in light of the LOB rules. Canada does not have a formal treaty benefit certification process to assist Canadian payors, unlike the W-8 BEN form requirements in the US.

Tim Wach, senior tax partner of Gowling Lafleur Henderson, has joined Finance Canada for a 20-month assignment as director of legislative development and chief legislative counsel.

The Australian treasurer has approved the move of James Hardie Industries's tax domicile from the Netherlands to Ireland after it assured him it would continue to make payments to an asbestos compensation fund in Australia after the change took effect.

Central European law firm Schoenherr has boosted its tax practice with two new junior partners.

Caitriona McGonagle has joined William Fry Tax Advisors - Taxand in Ireland as a consultant. She was formerly a partner at Matheson Ormsby Prentice, which she left in April.

UK taxpayers are concerned that the country's corporate tax rate will increase following next year's general election, a poll has said.

The UK's Treasury minister has outlined plans to reduce tax avoidance, by targeting companies that pay tax on a "do it yourself" basis.

The Dutch government has announced plans to change participation exemptions rules in a bid to improve the country's investment climate.

International Tax Review's weekly round-up of tax agreements from around the world.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Joint Venture £2.13 billion ($3.5 billion) British Land/Blackstone Group SJ Berwin Heather Corben (British Land) Simpson Thacher Bartlett (Blackstone Group) Acquisition Undisclosed Solera Holdings AUTOonline Hengeler Mueller Share Acquisition Undisclosed JCDecaux Wall AG Hengeler Mueller Ernst-Thomas Kraft Real Estate Undisclosed MACSF Triangle de l'Arche Fidal & Gide Loyrette Nouel Linklaters Edouard Chapellier & Aurelie Clementz Acquisition Undisclosed SPIE EI.WHS Gide Loyrette Nouel Anthony Davis, David Klass & Gerard Bracken Share Acquisition Undisclosed BAE Systems VT Group's shares in BVT Surface Fleet Freshfields Bruckhaus Deringer Sarah Falk & May Smith Real Estate Undisclosed Corpus Sireo Nörr Stiefenhofer Lutz Michaela Engel Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Underwriting Agreement Undisclosed Huntington Bancshares Goldman Sachs Wachtell, Lipton, Rosen & Katz T Eiko Stange If you would like to raise the profile of your firm, please send deal information to Jack Grocott (jgrocott@euromoneyplc.com).