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Shaun Connolly (pictured below), of Russell McVeagh, provides guidance for taxpayers on reducing the risks of tax dispute in New Zealand and how to deal with any that do arise.

FAS 109; Australian R&D; Camp & Levin; US/EU trade agreement; US FTT; US SC PPL; Hong Kong disputes

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Share Buy-back $15.95 billion BPCE Natixis Bredin Prat - Yves Rutschmann Bredin Prat - Yves Rutschmann Acquisition $4.3 billion Linn Energy Berry Petroleum Latham & Watkins Wachtell, Lipton, Rosen & Katz - Eiko Stange Acquisition $2.56 billion Orix Robeco De Brauw Blackstone Westbroek Acquisition $2.1 billion Bancolombia HSBC (Panama) Sullivan & Cromwell - David Spitzer, Davis Wang Linklaters / Arias, Fábrega & Fábrega Acquisition $1.4 billion TSYS NetSpend King & Spalding - John Sweet Fried, Frank, Harris, Shriver & Jacobson Merger $1.17 billion Office Depot OfficeMax Simpson Thacher & Bartlett / Kirkland & Ellis Skadden, Arps, Slate, Meagher & Flom / Dechert Acquisition $550 million MSC Industrial Barnes Group (US distribution business) Curtis, Mallet-Prevost, Colt & Mosle Acquisition $246 million Crestview Partners KeyCorp (Victory Capital Management/Advisers) Davis Polk & Wardwell - Kathleen Ferrell Sullivan & Cromwell - Ronald Creamer TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Credit Facilities $7 billion Freeport-McMoRan Copper & Gold JPMorgan Chase Davis Polk & Wardwell - Kathleen Ferrell / Jones, Walker, Waechler, Poitevent, Carrière & Denègre Cravath, Swaine & Moore Block Trade $1.5 billion LyondellBasell Industries Goldman Sachs Baker Botts Davis Polk & Wardwell - Michael Farber Common Shares and Depositary Share Offerings $1 billion Cliffs Natural Resources J.P. Morgan / Merrill Lynch / Citigroup Jones Day Davis Polk & Wardwell - Michael Farber High-yield Notes Offering $1 billion Flextronics International Merrill Lynch / Citigroup / J.P. Morgan Curtis, Mallet-Prevost, Colt & Mosle / Allen & Gledhill Davis Polk & Wardwell - Po Sit

The Chinese government may introduce a tax on carbon dioxide emissions that will reward taxpayers who invest in projects that enhance environmental protection. However the timing of the implementation of the tax may depend on balancing the interests of the tax and environment authorities.

Type of Agreement Country Country Date Signed Automatic Information Exchange Agreement Isle of Man UK February 19 2013

The French government will reassess how effectively information is exchanged with bilateral treaty partners to reduce the loss of revenue through cross border transactions.

Vladimir Starkov, a transfer pricing and asset valuation specialist, has become a vice president of NERA, the economics consultancy, in Chicago.

With its recent launch of an advance pricing arrangement (APA) programme and the strengthening of its transfer pricing assessment resources, Hong Kong's Inland Revenue Department (IRD) has made it clear where its future focus lies. Tracy Ho, of Ernst and Young (pictured below), outlines what other IRD challenges Hong Kong taxpayers can expect and how to deal with any tax disputes that arise.

PPL Corporation (PPL) kicked off its appeal over the creditability of UK windfall tax for US foreign tax credit purposes in the US Supreme Court yesterday. If the judgment causes uncertainty about which foreign taxes are creditable in America it could affect the way US taxpayers invest abroad.

French pharmaceutical multinational Sanofi’s victory in the Andhra Pradesh High Court shows the retrospective amendments to India’s tax laws cannot override the provisions of a tax treaty and sends a strong signal to foreign investors that India’s judiciary will uphold their interests.