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  • Deals 1998: a behind the scenes guide

    1998 was a busy year for M&A. The International Tax Review insiders’ guide takes you into the heart of the deals, with advisers from Allen & Overy, Haarmann, Hemmelrath & Partner, Sullivan & Cromwell, Davis, Polk & Wardwell and Tory, Tory, Deslauriers & Binnington

  • Deals 1998: a behind the scenes guide - US tax aspects of the BP/Amoco transaction

    During 1998 a number of very large cross-border tax-free acquisitions of US public corporations by foreign public corporations were completed. One of the largest was the acquisition of Amoco Corporation, a major US integrated oil company, by British Petroleum.

  • Deals 1998: a behind the scenes guide - Marriott and Sodexho avoid anti-Morris Trust treatment

    A potential acquirer is often interested in using its stock to purchase a certain portion of a US target's businesses. In this circumstance, the acquisition commonly employs the so-called "Morris Trust" structure. In such a structure, the target corporation first distributes the stock of a controlled subsidiary (which would typically hold all of the target's "unwanted" businesses) to its shareholders, and then, holding only the desired business, the target corporation is acquired for stock by the acquiring corporation.

  • Deals 1998: a behind the scenes guide - Sumitomo’s Aurora CLO

    The London branch of The Sumitomo Bank, Limited completed its Aurora corporate loan securitization in April 1998. Many corporate loan securitizations (otherwise known as collateralized loan obligations, or CLOs) involve complicated structures.

  • Deals 1998: a behind the scenes guide - Canada: cross-border acquisitions and exchangeable shares

    Specific international agreements and general trends toward global economic consolidation mean that Canadian business is now more than ever an important part of a highly integrated north American – and increasingly globalized – economy. Nevertheless, unlike the situation in the EU, the Canadian income tax system has undergone little if any change to harmonize its application with the tax systems of its major trading partners.

  • Deals 1998: a behind the scenes guide - Germany: step-up after an acquisition

    Amongst other goals, such as deduction of borrowing costs or tax-efficient unwinding, the additional step-up depreciation of the underlying assets is an important factor in any acquisition. The tax savings of such additional depreciation increase the cash flow of the target and, therefore, are essential for financing an acquisition.


Features

  • Deals 1998: a behind the scenes guide

    1998 was a busy year for M&A. The International Tax Review insiders’ guide takes you into the heart of the deals, with advisers from Allen & Overy, Haarmann, Hemmelrath & Partner, Sullivan & Cromwell, Davis, Polk & Wardwell and Tory, Tory, Deslauriers & Binnington

  • Argentina tightens fiscal grip

    Argentina's tax reform programme has introduced key changes in VAT, transfer pricing and income tax. But as Jorge San Martín and Hugo N Almoño of Price Waterhouse, Buenos Aires argue, the commitment to neutrality has been weakened

  • Big five prosper in the gloom

    As the world moves towards possible recession, International Tax Review reveals the big five revenue figures for 1998. Rosie Murray-West talks to the global heads of tax and asks them how they prosper in the face of adversity

  • Deals 1998: a behind the scenes guide - US tax aspects of the BP/Amoco transaction

    During 1998 a number of very large cross-border tax-free acquisitions of US public corporations by foreign public corporations were completed. One of the largest was the acquisition of Amoco Corporation, a major US integrated oil company, by British Petroleum.

  • Deals 1998: a behind the scenes guide - Marriott and Sodexho avoid anti-Morris Trust treatment

    A potential acquirer is often interested in using its stock to purchase a certain portion of a US target's businesses. In this circumstance, the acquisition commonly employs the so-called "Morris Trust" structure. In such a structure, the target corporation first distributes the stock of a controlled subsidiary (which would typically hold all of the target's "unwanted" businesses) to its shareholders, and then, holding only the desired business, the target corporation is acquired for stock by the acquiring corporation.

  • Choosing the best of the bunch in Japan

    Foreign investors in Japan face myriad options in their search for tax-efficient flow-through structures. Dean A Yoost and Richard Elliott of PricewaterhouseCoopers, Tokyo explore the possibilities

  • Changing world leaves PE standing

    The permanent establishment concept is central to the taxation of businesses operating in more than one country. But the structures used have moved on since the original 1963 OECD definition. Oliver Ralph examines the pressing need for a reformulation

  • Deals 1998: a behind the scenes guide - Sumitomo’s Aurora CLO

    The London branch of The Sumitomo Bank, Limited completed its Aurora corporate loan securitization in April 1998. Many corporate loan securitizations (otherwise known as collateralized loan obligations, or CLOs) involve complicated structures.

  • Deals 1998: a behind the scenes guide - Canada: cross-border acquisitions and exchangeable shares

    Specific international agreements and general trends toward global economic consolidation mean that Canadian business is now more than ever an important part of a highly integrated north American – and increasingly globalized – economy. Nevertheless, unlike the situation in the EU, the Canadian income tax system has undergone little if any change to harmonize its application with the tax systems of its major trading partners.

  • Rulings bring US-Mexico opportunities

    Decisions in Mexico and the US allow Mexican entities to cut their assets tax base and banks to reduce reporting requirements. By Miguel Valdés, Nicolás José Muñiz, Frederico Aguilar and Jorge García of Ernst & Young in New York and Mexico City

  • India doubles tax avoidance difficulties

    Two recent rulings by India’s Authority for Advance Rulings have done little to clarify interpretation of Double Tax Avoidance Agreements by the courts. Bobby Parikh and Keyur Shah of Arthur Andersen, Mumbai, set out the cases, and discuss the points of contradiction

  • Deals 1998: a behind the scenes guide - Germany: step-up after an acquisition

    Amongst other goals, such as deduction of borrowing costs or tax-efficient unwinding, the additional step-up depreciation of the underlying assets is an important factor in any acquisition. The tax savings of such additional depreciation increase the cash flow of the target and, therefore, are essential for financing an acquisition.

  • Hong Kong keeps expats in tax net

    The tax issues of structuring inbound and outbound expatriate contracts in Hong Kong centre on the test of location of employment. Ian Love, PricewaterhouseCoopers, Hong Kong sets out the pitfalls and opportunities to be addressed


News Analysis

  • Allen & Overy wins Gide partners. Gide cries foul

    French law firm Gide Loyrette Nouel is reeling from the shock of losing six of its partners to UK law firms. Among them was tax partner Siamak Mostafavi, who has become Allen & Overy's first tax partner in Europe.

  • Brazil risks IMF crisis

    Struggling Brazil may lose R$7 billion ($2.7 billion) in tax revenue because of a complicated legislative process. This would result in the country missing budget targets negotiated with the International Monetary Fund.

  • China taxes development zones

    China's finance minister, Xiang Huaicheng, has announced the end of the mainland's development zones, which are the country's main incentive attracting foreign investors.

  • Letter to the editor

    From: Steve Towers Partner, Deloitte Touche Tohmatsu, Melbourne, Australia.

  • PricewaterhouseCoopers merges in Spain to compete with Garrigues & Andersen

    Following in the footsteps of its competitor Arthur Andersen, which in 1997 merged with Spanish law firm J&A Garrigues, PricewaterhouseCoopers has announced a merger with the Madrid office of Spanish law firm Mullerat & Roca. "The system of Garrigues & Andersen is the right way to increase our presence in the legal market," says Antonio Lewis Vañon, head of the legal practice at PricewaterhouseCoopers.

  • Temporary reprieve from Michigan taxes

    The US state of Michigan has granted foreign businesses a brief respite from recent harsh tax changes. But this temporary measure may not be enough to appease Canadian companies who are calling for an exemption from the new rules.

  • US-UK eye treaty renegotiations

    Both the US Treasury Department and the UK Inland Revenue have announced that they will schedule meetings early next year for the purpose of renegotiating the existing income tax treaty, which has been in effect since 1975.

  • UK releases APA proposals

    The UK Inland Revenue has released proposals for an advance pricing agreement (APA) system. The proposals come as part of the general review of transfer pricing which was announced in the March 1998 budget.

  • News in brief

    Australian tax breaks cause controversy, PwC loses ground in Latin America, Japan proposes largest-ever tax reductions, Cartel probe follows PwC Italy merger, Italian government signs tax reform pact, Taxman freezes Pakistan's press, Russia placates regions with tax split deal

  • Astra-Zeneca super deal gets top advisers

    Swedish pharmaceutical group Astra is to merge with UK pharmaceutical company Zeneca. The deal will create the largest pharmaceutical group in Europe, with a market capitalization of $70 billion. This is the largest merger ever to be performed in Europe.

  • Herbert Smith tackles burning issues

    British American Tobacco is to acquire Rothmans for $8.6 billion. The new group will have 16% of the world market, and will sell 900 billion cigarettes each year.

  • Correction

  • Freshfields and Linklaters power ahead

    Electricity utility PacifiCorp of the US has announced an agreed merger with ScottishPower of the UK.

  • Beiten, Burkhardt are the medicine men

    The Frankfurt office of Beiten, Burkhardt, Mittl & Wegner advised Mediclin AG in its takeover of the Hurrie clinics group.

  • Cravath, Swaine & Moore in magazine deal

    New York firm Cravath, Swaine and Moore is advising UK publisher Emap on the acquisition of US magazine publisher Petersen.

  • euro899 million offering from Fortis

    The Fortis banking and insurance group is making an offering of 25 million ordinary shares with expected proceeds of euro899 million.

  • Sullivan and Cromwell aids communication

    New York firm Sullivan & Cromwell is advising SBC Communications in the acquisition of Comcast Corporation's wireless subsidiary.

  • Lovell White Durrant claims insurance deal

    The London office of Lovell White Durrant is representing Australian insurance group AMP in a deal valued at £2.7 billion ($4.3 billion).

  • Akin, Gump advises Clear Channel

    US radio and television company Clear Channel Communications is acquiring Jacor Broadcasting of Colorado. The deal is valued at $4.4 billion.

  • Skadden, Arps in Silicon Sale

    Skadden, Arps, Slate, Meagher and Flom is assisting internet service provider America Online in its acquisition of Netscape.

  • Linklaters and Freshfields scoop British Aerospace deal

    British Aerospace has made an agreed £7.8 billion ($12.48 billion) bid for General Electric's defence group, GEC Marconi. The stock and debt acquisition will create the world's third-largest defence company.

  • Taxfax

    Canciello accomplishes all at IRS , Dogs carry Belgrade tax penalty, Happy birthday dear income tax, Taylor finds haven at Deloitte, Pink palace tested for dodgy foundations


International Correspondents


International Tax Review Profile

RT @BrigitteAlepin: So proud of the new book WINNING THE TAX WARS. Bringing together well-known tax experts, this book presents outstanding…

Dec 7 2017 04:08 ·  reply ·  retweet ·  favourite
International Tax Review Profile

REVEALED: The top 10 of ITR's #GlobalTax50 2017 is out now. Find it here: https://t.co/IXiaRrE3vH (subscription or free trial required)

Dec 7 2017 01:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

ITR has opened the submissions period for the European Tax Awards 2018. Full details here: https://t.co/WKBWijhBgt

Dec 6 2017 01:40 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@aloysrigaut @AuroChardon @ElodieLamer @JeanComte @diego_bxl @bsmithmey @afpfr @pierremoscovici @EU_Taxud @EU2017EE… https://t.co/oS4sDvQtdL

Dec 5 2017 04:55 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Is this it? https://t.co/O1XhoWQw2F 17 #taxhavens, mostly tiny countries or emerging economies on the #EUblacklist? ❌Swit…

Dec 5 2017 02:25 ·  reply ·  retweet ·  favourite
International Correspondents