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  • Foley & Lardner has expanded its tax practice in Silicon Valley with the hire of new partner Fred Adam.
  • Patrick Connolly has joined DLA Piper as a partner in the firm’s tax practice in Los Angeles.
  • Irish taxpayers will be requested to perform a self-review of their compliance with the Irish transfer pricing rules under a new initiative announced by the Irish Revenue Commissioners.
  • The Canada Revenue Agency (CRA) has issued a transfer pricing memorandum, endorsing the OECD’s arm’s-length principle and including significant changes in the Canadian transfer pricing regime.
  • Ireland-US FATCA agreement; UK & Ireland tax accounting standards; UK Autumn Statement; Germany-Switzerland tax agreement; Indian reverse charge mechanism; OECD VAT guidelines; Holding companies and VAT groups; and Strategic dividend distribution.
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Taiwan Thailand November 30 2012 Double Taxation Avoidance Agreement Bahrain Barbados December 3 2012 Tax Information Exchange Agreement Cayman Islands Italy December 3 2012
  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $2.8 billion Baxter International Gambro Kirkland & Ellis / Vinge Linklaters Cooperation Agreement $1.94 billion TenneT TSO Statnett / KfW IPEX-Bank Hengeler Mueller - Martin Klein Acquisition $1.45 billion Global Logistic Properties Prosperitas Investimentos Lefosse Advogados - Gustavo Haddad, Bruno Carramaschi Acquisition $1.45 billion Saputo Morningstar Foods Jones Day / Stikeman Elliott Skadden Arps Slate Meagher & Flom Merger $708.4 million PMI Gold Keegan Resources Stikeman Elliott - John Lorito, Katy Pitch McMillan Merger $668 million TD Bank Group Epoch Holding Simpson Thacher & Bartlett Skadden, Arps, Slate, Meagher & Flom Acquisition $555.7 million Osisko Mining Queenston Mining Fraser Milner Casgrain Stikeman Elliott - Dean Kraus, John O’Connor Acquisition $500 million Harry Winston Diamond Mines BHP Billiton (EKATI Diamond Mine) Borden Ladner Gervais Davies Ward Phillips & Vineberg Acquisition $287.7 million U-Shin Valeo (Access Mechanisms Business) Davis Polk & Wardwell Acquisition $165 million Onex BBAM Davis Polk & Wardwell - Mary Conway, Gregory Hannibal TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Refinancing $1.25 billion OSI Group Hengeler Mueller Notes Offering $287.5 million Comcast Merrill Lynch / Morgan Stanley / UBS / Wells Fargo Davis Polk & Wardwell - Rachel Kleinberg Cahill Gordon & Reindel Offer For Sale $174.8 million Blue Dart Express Citigroup Linklaters Amarchand Mangaldas / Cleary Gottlieb Steen & Hamilton Qualified Institutional Placement $159.5 million Mahindra and Mahindra Financial Services Kotak Mahindra / Citigroup / Deutsche / HSBC / JM Financial Khaitan & Co Amarchand Mangaldas / Jones Day Share Offering $94 million OceanaGold Citigroup / Macquarie Capital Fasken Martineau / Allens Linklaters / Sullivan & Cromwell King & Wood Mallesons / Stikeman Elliott / Dorsey & Whitney
  • Michael Noonan, Ireland’s Finance Minister, reiterated the country’s commitment to its 12.5% corporate income tax rate last week. The commitment was the headline announcement in the country’s latest austerity budget.
  • Ireland has become the latest jurisdiction to agree to an intergovernmental agreement (IGA) with the US to implement the Foreign Account Tax Compliance Act (FATCA).
  • Tax accounting standards will change in the UK and Ireland as a result of the publication of FRS 100 Application of Financial Reporting Requirements by the Financial Reporting Council (FRC).