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Allen & Overy has added one more partner to its tax department in Paris.

Sean Foley Landon McGrew The IRS recently issued a directive (LMSB-4-0510-017) providing taxpayers with a favourable opportunity to correct certain errors in a timely filed gain recognition agreement (GRA) without having to request reasonable cause relief. The directive, effective as of July 26 2010, indicates that it may be withdrawn at anytime. Therefore, taxpayers should carefully review their outstanding GRAs as soon as possible to consider whether relief under the directive is warranted.

Cenk Ulu Cem Araci The use of electronic tools promises to make commercial and bureaucratic transactions efficient and compliant in the future. We are moving towards a system where all the official processes regarding commercial and social order are recorded electronically. The E-State project in Turkey is the infrastructure of the concept by which public services and transactions are carried to the electronic environment. Within this system, speed and convenience are the objectives, an effective audit function would be established and integration between institutions and processes would be achieved. The E-State project has led to rapid transformation and success in many fields including tax and accounting practices. The Ministry of Finance is also pursuing improvements in established systems through mechanisms such as electronic bookkeeping and electronic invoicing.

Mika Persson Jacob Mattsson On August 30 2010 the Swedish tax agency gave its view on the application of one of the escape clauses under the interest deduction limitation rules, the so-called 10% rule.

Daniel Armesto The potential impact of the Spanish inheritance and gift tax (IGT) has traditionally been an influencing factor in shaping the ownership structure of properties in Spain belonging to nonresident individuals. However recent legal developments in Spain regarding both nonresident income tax (NRIT) and IGT may impact the way that such investments are structured in the future. In some cases nonresidents may be entitled to claim a refund of Spanish taxes previously paid to the Spanish revenue in connection with transfers of Spanish properties.

South Africa's Taxation Laws Amendment Bill has radically altered the country's transfer pricing and thin capitalisation rules.

The California Court of Appeal held that a state law which subjects taxpayers to a penalty for a tax understatement in excess of $1 million is constitutional.

Pawel Szymanski Amendments to the Polish corporate income tax regulations refer, among other things, to exemptions from taxation of dividends that comply with the EU Directive 90/435/EWG.

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Australia Mauritius December 8 2010 Tax Information Exchange Agreement Argentina China December 13 2010

On September 8 2010 the Mexican government released a proposed tax bill which contains certain modifications to tax law.