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  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $1.46 billion DDR Corp. Blackstone Jones Day Simpson Thacher Acquisition $995.4 million United Engineers WBL Corporation Rajah & Tann WongPartnership Acquisition $890 million CITIC Capital Partners AsiaInfo-Linkage Davis Polk & Wardwell - John Paton Shearman & Sterling Merger $835 million True Religion Apparel TowerBrook Capital Partners Greenberg Traurig / Akin Gump Strauss Hauer & Feld Wachtell, Lipton, Rosen & Katz - Jodi Schwartz Acquisition $571.2 million Mirvac Group GE Real Estate Investments Australia (office portfolio) Corrs Chambers Westgarth / Norton Rose King & Wood Mallesons Acquisition $290.4 million Piramal Enterprises Shriram Transport Finance Company Amarchand Mangaldas Joint Venture $227.8 million Far East Orchard Toga Pty WongPartnership / King & Wood Mallesons Clifford Chance / Corrs Chambers Westgarth Acquisition $223 million Palisade Investment Partners / Northleaf Capital Partners EnergyAustralia (Waterloo wind farm) Baker & McKenzie King & Wood Mallesons Acquisition Undisclosed Bain Capital FTE automotive Group Hengeler Mueller - Matthias Scheifele Acquisition Undisclosed Meredith Bonnier (Parenting and Babytalk magazines) Belin McCormick Davis Polk & Wardwell - Kathleen Ferrell Acquisition Undisclosed RelayRides Wheelz Fenwick & West TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Notes Offering $3 billion Statoil Deutsche Bank / J.P. Morgan / Morgan Stanley / RBS Sullivan & Cromwell Wikborg, Rein & Co. / Davis Polk & Wardwell Secondary Offering $967 million Vantiv J.P. Morgan / Credit Suisse / Goldman, Sachs / Morgan Stanley / Deutsche Bank Weil, Gotshal & Manges Davis Polk & Wardwell - Harry Ballan Senior Notes Offering $750 million Covidien International Finance Barclays / Merrill Lynch / Morgan Stanley Gibson, Dunn & Crutcher / Allen & Overy / Arthur Cox / Appleby Davis Polk & Wardwell - Samuel Dimon Initial Public Offering $438.6 million Virtus Health King & Wood Mallesons Ashurst Zero Coupon Convertible Bonds Offering $220 million Asia Cement Corporation Goldman Sachs / Merrill Lynch / BNP Paribas Lee and Li Davis Polk & Wardwell Initial Public Offering $200 million Capitol Acquisition Corp. II Citigroup / Deutsche Bank Graubard Miller Davis Polk & Wardwell - Gregory Hannibal Secondary Offering $196.8 million Webster Financial Corporation Deutsche Bank / J.P. Morgan Wachtell, Lipton, Rosen & Katz Davis Polk & Wardwell - Samuel Dimon Common Stock Offering $171 million Isis Pharmaceuticals Goldman, Sachs / J.P. Morgan Cooley Davis Polk & Wardwell - Rachel Kleinberg
  • The dust has finally settled on the quick-fire legislation introduced to encourage tax compliant behaviour among groups which are suppliers to the UK government. The outcome is that the government has introduced an additional set of questions to be answered by suppliers during the selection process, to reject companies found to be engaging in attempted tax avoidance.
  • After the UK’s HM Revenue & Customs (HMRC) received such negative press from the Public Accounts Committee (PAC) for its approach to transfer pricing, the tax authority has released a briefing, intended to clarify its practice. But, when it is public opinion which seems to matter most in the PAC debate, it is unlikely civil society will read the statement, say advisers.
  • A transfer pricing adjustment imposed on Kodak India, relating to its medical imaging business, has been overturned in the Mumbai bench of the Income Tax Appellate Tribunal (ITAT). The case is one of a growing number of adjustments made using methods that are not prescribed under Indian legislation.
  • Taxpayers with a permanent establishment (PE) in India can use a profit attribution method described in the Delhi Income Tax Appellate Tribunal’s (ITAT) Convergys judgment to guide their behaviour in what remains an area of legal uncertainty in India.
  • President Obama has appointed Daniel Werfel as acting commissioner of the Internal Revenue Service.
  • The US have published new versions of the intergovernmental agreements (IGA) that have become the main instruments for the implementation of the Foreign Account Tax Compliance Act (FATCA).
  • Rosneft, the Russian energy company, was named as European in-house team of the year for direct tax at International Tax Review’s European Tax Awards last night.
  • Sarah Priestley has left Weil, Gotshal & Manges in London, where she was head of the corporate tax group, to join Shearman & Sterling in the same city.
  • Germany’s intent to incorporate mandatory binding arbitration provisions in current and future double taxation agreements (DTA) should allow taxpayers to eliminate the risk of double taxation in cross-border cases and help them exert pressure on tax authorities to reduce the length of disputes.