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As the planning opportunities for avoiding, deferring or sheltering taxable gain on asset dispositions continue to be curtailed through changes in tax law and administration, taxpayers have turned to partnership transactions to accomplish these goals. Michael Sabbah, associate at Wachtell, Lipton, Rosen & Katz, explains why new proposed IRS regulations could limit the use of these types of transactions.

The opposition Labour Party has slammed the Coalition government’s VAT rise. Labour is on course to win the next election. But will it lower VAT?

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $2.9 billion Forest Labs Aptalis (TPG Capital) Debevoise & Plimpton; Cleary Gottlieb, Steen & Hamilton; Stikemann Elliott - Vince Imerti, Dean Kraus Ropes & Gray Acquisition $1.7 billion Smith & Nephew ArthroCare Corp Davis Polk & Wardwell - Kathleen Ferrell Acquisition Undisclosed Vector Capital CollabNet Davis Polk & Wardwell - Rachel Kleinberg, Catherine Paskoff Chang Wilson Sonsini Goodrich & Rosati Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Global bond offering $2 billion Province of Ontario Deutsche Bank; Goldman Sachs; Merrill Lynch; TD Securities Shearman & Sterling Davis Polk & Wardwell Notes offering $600 million Textron JP Morgan Securities; Citigroup Global Markets Pillsbury Winthrop Shaw Pittman Davis Polk & Wardwell - Michael Farber Convertible bonds offering $460 million Acciona HSBC; Credit Agricole; RBS; Societe Generale Slaughter and May - Tony Beare, Shofiq Miah; Uria Menendez - Jesus Lopez Tello, Roberto Medrano Common stock offering $444 million Rexnord Corporation Goldman Sachs; Robert W Baird; Credit Suisse Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Samuel Dimon, Rachel Lerner Senior notes offering $400 million Legg Mason JP Morgan Securities; Citigroup Global Markets Davis Polk & Wardwell - Po Sit Shearman & Sterling Common stock offering $360 million XPO Logistics Credit Suisse; Citigroup; Deutsche Bank; JP Morgan Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Kathleen Ferrell, Isaac MacDonald Block trade $251 million BankUnited Goldman, Sachs & Co Skadden, Arps, Slate, Meagher & Flom; Simpson Thacher & Bartlett; Weil, Gotshal & Manges Davis Polk & Wardwell - Michael Mollerus, Patrick Sigmon Initial public offering $188 million Intrawest Resorts Holdings Goldman Sachs; Credit Suisse; Deutsche Bank; Merrill Lynch Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Harry Ballan, Ameya Bapat Secondary offering $48 million Centene Corporation Barclays Capital Bryan Cave; Jaffe Raitt Heuer & Weiss Davis Polk & Wardwell - Michael Farber, Patrick Sigmon

Morris Maroon has joined Rockwell Olivier as head of tax. He will work from the Sydney office, leading a team that advises businesses and professional advisers on all areas of Australian domestic and international tax law and also assists clients and accountants to resolve complex disputes with the Australian Tax Office (ATO).

Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implications, which must be considered by any multinational in this position.

The OECD issued a draft revised chapter V of the OECD guidelines on documentation on January 30 2014. The emphasis is now on both transfer pricing enquiry and on risk assessment. One of the key changes to help tax authorities with risk assessment is the introduction of guidance on country-by-country reporting (CBCR).

Permanent establishment (PE) is becoming more complicated as regulators find it hard to keep pace with a rapidly developing digital economy. Taxpayers regularly find themselves in difficulty trying to decide whether certain operations in certain jurisdictions constitute a PE but the consequences of getting it wrong could mean big transfer pricing adjustments for multinational companies. This selection of articles gives an overview of some of the most topical issues surrounding PE.

Brad Rolph of Grant Thornton and Claire Kennedy of Bennett Jones review the decision of the Tax Court of Canada in McKesson Canada Corporation v HM The Queen, describe approaches to pricing factoring arrangements and highlight some of the key lessons for multinationals from this case.

This article is the first in a monthly column on tax and technology issues for 2014. Companies that operate globally have a wide range of challenges and issues to consider, explain Vertex.

Tax executives are feeling the heat as governments around the world increase enforcement, initiating more audits and disputes. Some, though by no means a majority, believe a concept known in different jurisdictions as horizontal monitoring, enhanced relationships or cooperative compliance may be the key to an improved relationship between both sides.