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DLA Piper in the UK has appointed Stephen Hoyle as a partner and head of UK tax.

Sean Foley Landon McGrew The Internal Revenue Service (IRS) recently issued an industry director directive on the Loss Importation Transaction providing for heightened audit scrutiny. A loss importation transaction was previously identified as a listed transaction in Notice 2007-57. As described in the notice and the directive, a loss importation transaction generally involves the use of offsetting foreign currency or other property positions by a US taxpayer to import a loss, but not the corresponding gain, into US taxable income. The IRS believes this is done in an attempt to exploit the entity classification rules and Internal Revenue Code section 951 (which provides when a US shareholder has to include in income his subpart F and related income).

South African residents pay tax on their foreign dividends. However, various exemptions apply. In particular, where a resident of South Africa holds at least 20% of the ordinary shares in the declaring company and various other conditions are met, the foreign dividends are exempt from tax in the hands of the South African resident recipient.

Vladimir Kotenko On July 8 2010 the Ukrainian Parliament adopted a resolution obliging the cabinet of ministers to pass the draft tax code for public discussion.

A country's tax policy is reflected in its domestic tax legislation as well as its tax treaty positions.

Marta Szafarowska Since a VAT was introduced in Poland in 1993 all goods and services subject to reduced VAT rates as well as exemptions have been defined through their statistical classification.

Gary Thomas The National Tax Agency has amended its transfer pricing guidelines to issue to its transfer pricing examiners concerning the implementation of Japan's new transfer pricing documentation rules as well as examinations of transactions involving joint venture companies.

Ugo Cannavale Transfer pricing documentation provisions have been included in Law number 122 published in the Official Gazette on July 30 2010.

Kathleen Penny Josh Jones Non-residents of Canada that dispose of taxable Canadian property (TCP) are taxable in Canada, subject to treaty relief. Before March 5 2010, all private Canadian corporations' shares were TCP. As of March 5 2010, Canadian shares are generally not TCP unless, at any time in the 60-month period preceding disposition, they derived more than 50% of their value directly or indirectly from Canadian real or resource property. On July 12 2010, the legislation implementing this change became law.

Joe Duffy Gerry Thornton Under a recently issued statement of practice, the Revenue Commissioners in Ireland have extended the exemption from Irish withholding tax for cross-border patent royalty payments. This development is a welcome step in enhancing Ireland's status as a location in which to develop, exploit and manage intellectual property (IP).