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The founder of KPMG’s US transfer pricing controversy practice has formed his own transfer pricing law practice.

The UN and the OECD are both working on important transfer pricing policy discussion reports and representatives from both organisations have said tax practitioners can expect significant developments in 2013.

Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Gibraltar India February 1 2013 Double Taxation Avoidance Agreement Poland US February 13 2013

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $28 billion Berkshire Hathaway / 3G Capital H.J. Heinz Company Kirkland & Ellis / Munger, Tolles & Olson Davis Polk & Wardwell - Kathleen Ferrell / Wachtell, Lipton, Rosen & Katz Acquisition $16.7 billion Comcast NBCUniversal Media (General Electric stake) Davis Polk & Wardwell - Avishai Shachar, Neil Barr / Willkie Farr & Gallagher Weil, Gotshal & Manges Acquisition $15.1 billion CNOOC Nexen Davis Polk & Wardwell Blake Cassels & Graydon / Paul Weiss Rifkind Wharton and Garrison Acquisition $4.59 billion RioCan REIT Primaris REIT Stikeman Elliott / Fogler Rubinoff McCarthy Tétrault / Cassels Brock & Blackwell State aid $2.68 billion French State PSA Peugeot Citroën Willkie Farr & Gallagher Bredin Prat Acquisition $2.07 billion Cardinal Health AssuraMed Wachtell, Lipton, Rosen & Katz - Deborah Paul Debevoise & Plimpton TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Senior Notes Offering $800 million Delphi J.P. Morgan / Merrill Lynch / Deutsche Bank / Barclays / Citigroup / Goldman Sachs Davis Polk & Wardwell - Michael Mollerus Cahill Gordon & Reindel NAB Convertible Preference Share Offering $750 million National Australia Bank National Australia Bank King & Wood Mallesons Herbert Smith Freehills Senior Notes Offering $700 million Republic of Guatemala HSBC Securities Davis Polk & Wardwell - Samuel Dimon Shearman & Sterling Senior Secured Notes Issue $668.9 million Labco Deutsche Bank / Barclays / Natixis Landwell / Kirkland & Ellis Bredin Prat - Julien Gayral / Cravath, Swaine & Moore Notes Offering $600 million Airgas Goldman Sachs / Merrill Lynch / Wells Fargo Cahill Gordon & Reindel Davis Polk & Wardwell - Rachel Kleinberg Senior Secured Notes Offering $300 million GeoPark Latin America Itau BBA USA / J.P. Morgan / Banco BTG Pactual Chadbourne & Parke / Cox Hallett Wilkinson / Barros & Errázurriz / Suarez Zapata Davis Polk & Wardwell / Carey y Cía / Gómez-Pinzón Zuleta Initial Public Offering $280 million Sprott Physical Platinum and Palladium Trust Morgan Stanley / RBC Capital Markets Heenan Blaikie Davies Ward Phillips & Vineberg Initial Public Offering $230 million Linx BTG Pactual / Credit Suisse / Itaú BBA USA / Morgan Stanley White & Case / Lefosse Advogados Pinheiro Guimarães Advogados / Davis Polk & Wardwell

In January, International Tax Review’s Matthew Gilleard reported on some reactions to a corporate tax reform proposal forwarded by Robert Pozen, senior lecturer at Harvard Business School and a senior fellow at the Brookings Institution, which would reduce the US corporate tax rate by limiting interest deductions. Here, Pozen responds to some of those objections.

UK government compliance; IAS 12; US bias for debt; Germany group taxation rules; EC FTT; OECD VAT; Amazon and Overstock; BNY Mellon

Australia yesterday introduced reforms aimed at boosting the government’s ability to tackle base erosion and profit shifting, including changes to the transfer pricing regime and general anti-abuse rule (GAAR).

The OECD has identified transfer pricing as one of the challenges for policy makers and taxpayers as they attempt to reform how international tax rules work.

Bank of New York Mellon (BNY Mellon) had its case thrown out by the US Tax Court this week as the court described a structured trust advantaged repackaged securities (STARS) scheme it was sold by Barclays in 2001 as an elaborate subterfuge for creating foreign tax credits.

Online retailers Amazon and Overstock are battling the New York State Department of Taxation and Finance in court over a requirement for remote sellers to collect state sales tax. The ruling will have an impact on companies operating throughout the US.