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  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Acquisition $20.1 billion Softbank Sprint Nextel Morrison & Foerster Skadden Arps Slate Meagher & Flom Acquisition $2.6 billion Cencosud Carrefour (Colombia) Philippi / Allen & Overy Baker & McKenzie / Bredin Prat Acquisition $2.54 billion ASML Holding Cymer Skadden, Arps, Slate, Meagher & Flom Sullivan & Cromwell - Ronald Creamer Acquisition $865 million ACE Group Ally Financial Sullivan & Cromwell - Andrew Solomon / Mayer Brown Acquisition $285 million Oiltanking GmbH Chemoil Energy WongPartnership Acquisition $282.9 million Homestead Land Holdings ELAD Canada Soloway Wright Stikeman Elliott Acquisition $166.1 million Kingdom Hotels Four Seasons Hotel Stikeman Elliott / Hogan Lovells Goodmans Acquisition $125 million Johnson Controls A123 Systems Wachtell, Lipton, Rosen & Katz - Eiko Stange Lazard / Alvarez & Marsal Merger $101 million BioCryst Pharmaceuticals Presidio Pharmaceuticals Wachtell, Lipton, Rosen & Katz - Deborah Paul Cooley TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Acquisition Financing $2.5 billion Cencosud JPMorgan Chase / National Association / JP Morgan Milbank, Tweed, Hadley & McCloy / Philippi / De Brauw Blackstone Westbroek / Posse, Herrera & Ruiz Carey y Cía / Nauta Dutilh / Martinez Neira / Davis Polk & Wardwell Equity Offering $1.25 billion Mexichem Citigroup / HSBC / JP Morgan / Morgan Stanley Davis Polk & Wardwell / White & Case Cleary Gottlieb Steen & Hamilton / Ritch Mueller Spinoff $1 billion Murphy Oil USA Davis Polk & Wardwell - Kathleen Ferrell Senior Notes Offering $400 million PPL Capital Funding Mitsubishi UFJ / Morgan Stanley / RBC Capital / Wells Fargo Davis Polk & Wardwell - Samuel Dimon Sullivan & Cromwell Convertible Senior Notes Offering $396.8 million Stillwater Mining Credit Suisse / Wells Fargo Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Lucy Farr, Harry Ballan
  • US banks' effective tax rates; Starbucks, tax and CSR; Business Roundtable criticises Washington; Sales tax struck down in Egypt; Portugal's plans for FTT; Canadian Supreme Court favours GSK; How to manage tax disputes in Italy
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Cyprus Estonia October 17 2012
  • October 15 is behind us, and many tax professionals are taking a much needed break. It’s time to relax for a day, watch the sun set, or maybe even eat something that did not come in a take-out bag. That sounds amazing…
  • The SC dismissed the appeal by the Canada Revenue Agency (CRA) of a ruling by the Federal Court concerning the deductibility of the price paid by GSK Canada to a Swiss related-entity. The CRA said the payment was not reasonable in the circumstances and a reasonable payment would have been that paid by generic companies.
  • Taxpayers in Egypt with open sales tax disputes will welcome the Supreme Constitutional Court’s judgment that the retroactive imposition of sales tax is unconstitutional.
  • The recently introduced German Act on Mediation and the introduction of a second senate of the Federal Tax Court with responsibility for VAT issues are giving German taxpayers plenty of food for thought in managing their disputes.
  • Starbucks has gone to great pains to boost its corporate social responsibility (CSR) credentials by trumpeting fair trade products and environmentally sustainable practices, but after a scandal over the amount of tax it pays in the UK sullied its reputation, other companies may look to avoid its mistake by placing tax at the heart of their CSR agendas.
  • The recent strengthening of Italy’s general anti-avoidance rule (GAAR) and a pledge from the tax authorities to increase the frequency of audits targeting multinational companies means dispute management is high on the agenda for Italian taxpayers. Antonio Tomassini and Alessandro Martinelli of DLA Piper speak with International Tax Review about what options taxpayers have.
  • The Canadian Supreme Court (SC) has today delivered its first transfer pricing decision, in a case involving GlaxoSmithKline (GSK).