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  • The EU is seeking to extend tax transparency reforms for banks and resources groups to all large public and private companies. The move to install country-by-country reporting (CBCR) disclosure requirements on companies is part of the EU’s crack-down on aggressive tax avoidance and evasion.
  • Dave Hartnett, formerly the most senior tax official at HM Revenue & Customs (HMRC), has landed a job at Deloitte.
  • BCA on Australian budget; SAT on secondments; US SC PPL ruling; Expert evidence in Canadian court rulings; FTT potential delay; Mexican VAT; beneficial ownership; compliance in UK public sector procurement.
  • The UK government is holding a consultation on how to change two aspects of its partnership tax rules, with the aim of preventing tax loss arising from when employment relationships are disguised through limited liability partnerships (LLPs) and from certain arrangements involving profit and loss allocation among partnership members.
  • Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Brunei Canada May 9 2013 Double Taxation Avoidance Agreement Ethiopia Portugal May 25 2013
  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $8.5 billion Actavis Warner Chilcott Latham & Watkins Matheson / Arthur Cox & Co. / Davis Polk & Wardwell - Michael Mollerus Acquisition $3.7 billion FountainVest Partners / Carlyle Asia Investment / CITIC Capital / China Everbright Focus Media Holding Fried Frank Harris Shriver & Jacobson / Sullivan & Cromwell Simpson Thacher & Bartlett Acquisition $1.1 billion Apax Partners Rue 21 Simpson Thacher & Bartlett / Richards Layton & Finger Kirkland & Ellis / Potter Anderson & Corroon / Ropes & Gray Acquisition $1.1 billion Yahoo! Tumblr Simpson Thacher & Bartlett Gunderson Dettmer Stough Villeneuve Franklin & Hachigian Acquisition $1 billion Vista Equity Partners Websense Kirkland & Ellis Cooley Acquisition $883 million Banco de Crédito e Inversiones City National Bank of Florida Sullivan & Cromwell - Ronald Creamer Acquisition $600 million EDF EN Canada / Enbridge Inc. Greengate Power Corp. (Blackspring Ridge Wind Project) Stikeman Elliott - Jean-Guillaume Shooner Acquisition $502.3 million Accelero Capital Holdings Manitoba Telecom Services (Allstream) Stikeman Elliott Acquisition $382.9 million Lend Lease Investment Management GPT Group (Erina Fair shopping centre) King & Wood Mallesons Allens Acquisition $194 million Bright Ruby Resources 231 Elizabeth Street (Investa) King & Wood Mallesons Herbert Smith Freehills Merger Undisclosed BSN Sports Herff Jones Weil, Gotshal & Manges - Chayim Neubort Acquisition Undisclosed Campbell Soup Plum Organics Davis Polk & Wardwell - Harry Ballan Jones Day Acquisition Undisclosed Goldman Sachs / Thomas H. Lee Partners CTI Foods Weil, Gotshal & Manges Gibson, Dunn & Crutcher Acquisition Undisclosed Ziff Davis NetShelter Fenwick & West - Adam Halpern, Ora Grinberg TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Notes Offering $6.5 billion Merck & Co. BNP Paribas / Deutsche Bank / J.P. Morgan / Morgan Stanley Fried, Frank, Harris, Shriver & Jacobson Davis Polk & Wardwell - Po Sit Initial Public Offering $1.1 billion China Galaxy Securities Goldman Sachs / J.P. Morgan / China Galaxy International Grandall Law Firm Clifford Chance / Davis Polk & Wardwell Senior Notes Offering $675 million Morgan Stanley Morgan Stanley Davis Polk & Wardwell - Lucy Farr Sidley Austin Convertible Senior Notes Offering $300 million Shutterfly Morgan Stanley / J.P. Morgan Fenwick & West / Latham & Watkins Davis Polk & Wardwell - Rachel Kleinberg Senior Notes Offering $250 million The AES Corporation Morgan Stanley Davis Polk & Wardwell - Michael Mollerus Shearman & Sterling
  • The new draft of Form W-8BEN-E, which non-US entities must complete for the purposes of the Foreign Account Tax Compliance Act (FATCA) and other US withholding tax rules, is substantially different from the previous version that came out a year ago, practitioners say.
  • A transfer pricing adjustment imposed on Honda’s Indian company, after fluctuations in the foreign exchange rate, has been overturned by the Delhi bench of the Income Tax Appellate Tribunal (ITAT).
  • Legal & General won PwC’s 2012 Building Public Trust award for the best tax reporting in the FTSE 100. The company’s tax team explains its approach to tax transparency and tax reporting, including why it has published country-by-country analysis of taxes borne and collected.
  • US multinationals should see their transaction costs reduced when investing in foreign jurisdictions following the Supreme Court’s judgment in favour of energy company PPL.