Herbert Smith is advising the UK's largest transport group, Stagecoach, on its purchase of Houston-based Coach USA. The purchase is valued at $1.8 billion, which includes the assumption of $571million of debt. This is Stagecoach's first US acquisition and gives the company a foothold in the North American transport sector. The deal is being financed through a $2.25 billion loan from Credit Suisse First Boston, JP Morgan and the Royal Bank of Scotland. Stagecoach will also later issue up to $1 billion in bonds and equity-related securities for refinancing.
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A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR