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  • Inversion deals between companies such as Medtronic and Covidien, and failed attempts such as Pfizer’s desired takeover of AstraZeneca, have brought inversion transactions to the forefront of global tax issues. While the US government argues that inversion deals are anti-competitive, many taxpayers feel they are faced with an unappealing US tax system and have no choice but to look elsewhere.
  • In the first part of International Tax Review's exclusive interview, Steven Ouwerkerk, global head of tax & treasury at APM Terminals, based in The Hague, Netherlands, talks about the need for in-house tax teams to maintain consistent engagement with the boardroom and CFO, and reveals what it is that keeps him up at night.
  • A recent report criticising Ireland’s economic growth plan – initially labelled as coming from the German Bundestag Finance Committee – has caused controversy and tension in Irish-German relations, but an analysis of the facts shows the report does not wholly represent German attitudes towards Ireland.
  • Mexican taxpayers will not have to file an annual tax report from 2015, but what it is being replaced with is highly controversial and means that the relationship between tax authorities and taxpayers is very difficult at the moment.
  • The Senate Finance Committee this week held a hearing on proposals to reform the taxation of multinational enterprises, and given the recent trend of US companies inverting abroad, the hearing unsurprisingly focused on dealing with inversions.
  • Foreign investors that are unfamiliar with Brazilian tax legislation may find it unusual, but Brazilian taxpayers have long been used to a system that imposes taxes on corporate revenues as well as on corporate profits.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $54.8 billion Shire plc AbbVie Inc. Davis Polk & Wardwell - Michael Mollerus Acquisition $175 million LinkedIn Corporation Bizo Inc. Fenwick & West - Adam Halpern, William Skinner Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Bridge Facility $5.7 billion Tyson Foods, Inc. Morgan Stanley Senior Funding, Inc. Davis Polk & Wardwell Weil, Gotshal & Manges Senior Notes Offering $3 billion Morgan Stanley Morgan Stanley & Co. LLC Davis Polk & Wardwell - Lucy Farr, Andrew Smith Sidley Austin Term Loan Facility $2.5 billion Tyson Foods, Inc. Morgan Stanley Senior Funding, Inc. Davis Polk & Wardwell Weil, Gotshal & Manges Notes Offering $1.25 billion Toyota Motor Credit Corporation Barclays Capital Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated and RBC Capital Markets, LLC Davis Polk & Wardwell - Lucy Farr, Rachel Kleinberg, Koonho Cho Notes Offering $1 billion CSX Corporation Citigroup Global Markets Inc., Credit Suisse Securities (USA) LLC, Morgan Stanley & Co. LLC and UBS Securities LLC Davis Polk & Wardwell - Harry Ballan, Adam Bedzow Shearman & Sterling Senior PIK Toggle Notes Offering $400 million MHGE Credit Suisse Securities (USA) LLC, Morgan Stanley & Co. LLC, BMO Capital Markets Corp., Jefferies LLC, Nomura Securities International, Inc., UBS Securities LLC and Apollo Global Securities LLC Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Harry Ballan, Tracy Matlock Senior Notes Offering and Capped Call Transactions $130 million The KEYW Holding Corporation RBC Capital Markets, LLC and Merrill Lynch, Pierce, Fenner & Smith Inc Alston & Bird, Holland & Knight Davis Polk & Wardwell - Po Sit, Lucy Farr, Aaron Weil Intial Shares Offering $130 million Alexander Forbes Group Holdings Ltd Deutsche Bank AG, London Branch, Morgan Stanley & Co. International plc and Rand Merchant Bank Bowman Gilfillan Inc., Davis Polk & Wardwell - John Paton, Omer Harel Freshfields Bruckhaus Deringer, Edward Nathan Nathan Sonnenbergs Inc.
  • Matthew Schnall has joined WilmerHale in Boston as a partner.
  • Oil and gas exploration company, Tullow Oil, has lost a case in the Ugandan Tax Appeals Tribunal (TAT) over a disputed capital gains tax (CGT) assessment of almost $500 million. The tribunal questioned the legality of a CGT exemption granted by the country’s former energy minister.
  • EXCLUSIVE: On Monday July 21 the OECD released the full version of the Standard for Automatic Exchange of Financial Account Information in Tax Matters, which requires financial institutions to report detailed financial account information to their governments, which then exchange such information automatically with other jurisdictions on an annual basis. The Standard developed by OECD in response to a mandate by the G20 was first presented to and endorsed by the G20 Finance Ministers in February 2014.