Number 1 - 2006 contains the following:
 

A very clear and readable overview of the changes regarding cost sharing regulations that have been proposed by the US Treasury Department and the Internal Revenue Service. This article discusses the developments of the US cost sharing regulations over the last 40 years and concludes with the authors' commentary on several of the proposed changes.

This article describes the possible consequences of several recent changes (particularly those in Canada) for the allowed profitability of R&D activities. Considering the focus on the alleged profitability of e.g. marketing and distribution activities, the author states his reasons for fearing that the high returns for R&D activities, needed to make their busines a success, are being diminished.

This article provides for an overview of the OECD Discussion Draft of the Report on the Attribution of Profits to a Permanent Establishemnt (Part IV (Insurance)). The author sets forth what type of activity an insurance company may perform and how the division of funtions and responsibilities between head offices and permanent establishments may vary from company to another.