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The EU member states introducing the financial transaction tax (FTT) may be forced to water down the European Commission’s proposal if they want to make it stick, after the EU Council’s legal service said part of the residence principle of the tax is incompatible with European law.

G20 leaders met in St. Petersburg last week, with international taxation once again high on the agenda.

IRS Chief of Appeals Sheldon Kay returned to private practice with Sutherland, Asbill & Brennan this month after two years with the tax authority. International Tax Review took the opportunity to catch up with Kay to discover the latest developments within the IRS Office of Appeals and to get some advice for taxpayers on resolving disputes more efficiently.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $130 billion Verizon Communications Vodafone Group (Verizon Wireless) Wachtell, Lipton, Rosen & Katz / Macfarlanes / Debevoise & Plimpton Simpson Thacher & Bartlett Acquisition $7.17 billion Microsoft Nokia Covington & Burling / Simpson Thacher & Bartlett Skadden Arps Slate Meagher & Flom Acquisition $1.8 billion Jarden Yankee Candle Greenberg Traurig Kirkland & Ellis Acquisition $1.6 billion Global Ports National Container Company Freshfields Bruckhaus Deringer Dentons Acquisition $1.1 billion Louisiana-Pacific Ainsworth Lumber Stikeman Elliott - Luc Bernier, Corine Di Maria / Jones Day / Orrick Herrington & Sutcliffe Goodmans / Skadden Arps Slate Meagher & Flom Acquisition $1.1 billion Parkway Properties Thomas Properties Group Hogan Lovells Skadden Arps Slate Meagher & Flom Acquisition $985 million Alliant Techsystems Bushnell Group Holdings Cravath Swaine & Moore Kirkland & Ellis Acquisition $616 million American Family Mutual Insurance Company Homesite Group Foley & Lardner Willkie Farr & Gallagher Acquisition $305.7 million Cementos Argos Lafarge Cementos Sullivan & Cromwell - Ronald Creamer Acquisition $262 million C.R. Bard Rochester Medical Weil, Gotshal & Manges - Helyn Goldstein Acquisition Undisclosed Instagram Midnox Fenwick & West - Adam Halpern, Larissa Neumann Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Term Loan Facilities $1.15 billion Spectrum Brands Credit Suisse / Deutsche Bank Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Harry Ballan Block Trade $492 million J.C. Penney Company Citigroup Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Gregory Hannibal

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Malta Ukraine September 4 2013

BEPS transparency and technology; Syria to stall G20 tax negotiation; Canada unfair collection rule; ECJ Aegis HMRC; Italy FTT; Shome GST; India Revenue versus taxpayers; US tax evasion deal with Switzerland

When choosing a specialist recruitment agency, the size of the company can have a significant impact on how far that agency can be trusted to deliver the work, says Izabela Hollander-Bolton of IBH Executive

David Burke (left) has joined Maples & Calder in Dublin as of counsel. He was formerly a partner of Mason Hayes & Curran. He advises companies, banks and investment funds and their advisers on the tax aspects of the structuring and implementation of capital markets, structured finance, asset finance and funds transactions in and through Ireland.

Germany’s Federal Ministry of Finance has published draft legislative regulations for determining profits of permanent establishments (PE) using the arm’s-length standard. But advisers are concerned the legislation will increase transfer pricing risks.

Skilled yet relatively low-cost manpower, the low cost of production, and a growing customer base are the key factors that have attracted multinational enterprises (MNEs) to India. Rahul Tomar and Kulvinder Makkar focus on the emerging transfer pricing issues and their influence on the companies in technology, media, and telecommunications (TMT) industry in India.