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  • The Italian government may postpone a rise in VAT until autumn to assess whether alternative ways of balancing the country’s fiscal deficit can be found.
  • Parthasarathi Shome, minister of state to the Indian finance minister, has said there are instances where retrospective approaches, by tax authorities, are inappropriate. He was speaking at an international tax conference at the Confederation of Swedish Enterprise last week.
  • Differences in guidance given by the UN and OECD transfer pricing manuals are putting taxpayers at risk of double taxation. Taxpayers should design a transfer pricing policy that acknowledges both sets of principles.
  • Last month, Deloitte beefed-up its transfer pricing practice in Indonesia by hiring seven senior managers and three assistant managers.
  • Since the early 1960s the US corporate tax structure has remained relatively similar, while the world around it has changed radically. But as the percentage of total US tax revenues contributed from the corporate income tax continues to shrink (at the same time as tax rates worldwide continue to drop), Congress is looking hard at what is going wrong. But Douglas Stransky, of Sullivan & Worcester, asks if it is looking in the right place.
  • The US Foreign Investment in Real Property Tax Act (FIRPTA) was established in 1980 for the purpose of withholding the estimated amount of taxes which may be due on the gain of the disposition of a US real property interest from foreign persons. Daniel Gross, CEO of Axis International Realty, explores the intricacies of the provision.
  • Ramon Esquives Espinosa, head of tax processes in the management and tax advisory unit of BBVA’s finance area, explores the status of tax transparency in Peru in light of recent changes on tax authority assessment and the wider, aggressive campaign by SUNAT to increase tax collection.
  • George Osborne, UK Chancellor of the Exchequer, said more progress has been made on countering tax secrecy and corporate tax evasion in the last 24 hours than in the previous 24 years. But conflicting messages could yet stall concrete agreements.
  • Hogan Lovells has hired Rupert Shiers from Herbert Smith Freehills to lead its direct tax disputes practice.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $5.71 billion Sobeys Safeway Canada Sullivan & Cromwell - Ronald Creamer, Davis Wang / Stewart McKelvey Latham & Watkins Acquisition $2.72 billion JBS Marfrig (Seara Brasil / Zenda) In-house counsel Lefosse Advogados Acquisition $2.5 billion Apollo Tyres Ltd Cooper Tire & Rubber Company Sullivan & Cromwell / Amarchand & Mangaldas & Suresh A Shroff & Co. Jones Day Acquisition $1.5 billion Gannett Belo Nixon Peabody / Paul Hastings Wachtell, Lipton, Rosen & Katz - Joshua Holmes Acquisition $1.45 billion Alberta Investment Management Corp. / OMERS Private Equity Inc. Vue Entertainment Stikeman Elliott - Benjamin Hudy / Ashurst Acquisition $1.15 billion AstraZeneca Pearl Therapeutics Latham & Watkins / Willkie Farr & Gallagher Greenberg Traurig Acquisition $733 million Atlas Resource Partners EP Energy E&P Company Wachtell, Lipton, Rosen & Katz - Joshua Holmes Akin Gump Strauss Hauer & Feld Merger Undisclosed Centerline Holding Company Hunt Capital Partners Paul Hastings Paul, Weiss, Rifkind, Wharton & Garrison / DLA Piper Acquisition Undisclosed SAP hybris Acquisition Undisclosed Western Financial Group Coast Capital Insurance Services Stikeman Elliott Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Secondary Offering $1.72 billion General Motors Citigroup / J.P. Morgan / Morgan Stanley Jenner & Block Davis Polk & Wardwell - Samuel Dimon Equity Units Offerings $1 billion Dominion Resources BofA Merrill Lynch / Goldman Sachs / J.P. Morgan / UBS McGuireWoods Davis Polk & Wardwell - Michael Farber Notes Offering $800 million Roper Industries J.P. Morgan / Merrill Lynch / Wells Fargo / Barclays Davis Polk & Wardwell - Rachel Kleinberg Simpson Thatcher & Bartlett Pro-rata Accelerated Renounceable Entitlement Offer $532 million ASX UBS Herbert Smith Freehills / Sidley Austin King & Wood Mallesons Secondary Offering $270 million Silica Holdings Morgan Stanley / Merrill Lynch / Simmons & Company International / Jefferies / Wells Fargo Kirkland & Ellis Davis Polk & Wardwell - Kathleen Ferrell