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Tom Seymour, PwC On August 13 2012, a 71 page Discussion Paper was released by a Government-appointed working group to canvass ways in which a cut to the company tax rate could be funded from within the business tax system.

Comprehensive US tax reform is long overdue.

Eylem Philippou and Rudina Hoxha, Eurofast Taxand The Corporate Income Tax Law of Albania states that expenses are deductible only if such expenses are incurred in generating profits, if they relate to the ordinary course of business, if they are reflected in accounting books by reducing the net assets, and if they can be documented. Such documentation, for the justification of expense, includes: a VAT invoice, a simple tax invoice and any other documentation prepared or issued in conformity with the instructions of the Minister of Finance for the implementation of the tax legislation.

John Leopardi and Emmanuel Sala, Blake Cassels & Graydon For decades, non-Canadian resident inter vivos trusts were not taxed in Québec on property income derived from Québec situated immovable property. Such trusts were only subject to federal tax at a maximum rate of 42.92%. Further to the Québec 2012-2013 Budget, Québec announced that non-Canadian resident inter vivos trusts (Specified Trust) will be liable to an additional 5.3% Québec income tax on income derived from the rental of immovable property situated in Québec (Specified Immovable Property), for a combined Canadian and Québec rate of 48.22%. Such inter vivos trusts will also be required to file a Québec tax return and compute rental income from the Specified Immovable Property separately from any other sources so that any losses from such other sources may not reduce the income earned in Québec from the Specified Immovable Property or vice-versa.

Hans-Martin Eckstein, PwC In an unusually rapid reaction, the finance ministry has included provisions in its Annual Tax Bill 2013 to adopt the "authorised OECD approach" to the taxable income of permanent establishments (PEs). This approach was formulated by the OECD in its PE report of July 22 2010 calling for internationally uniform PE taxation on the basis of equal treatment of branches, subsidiaries and partnerships. Fundamentally, each should establish its taxable income as though it were an independent legal entity trading at arm's-length with all related parties and fellow business units.

David Cuellar and Jose Antonio Gonzalez, PwC On May 14 2012 Mexico signed a new tax treaty with Qatar. The agreement will enter into force 30 days after the exchange of the ratification instruments takes place.

Baker & McKenzie has hired a new tax partner for its Washington, DC office.

TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Merger $506 million Columbia Banking System West Coast Bancorp Graham & Dunn Wachtell, Lipton, Rosen & Katz - Joshua Holmes Acquisition $165 million K-REIT Mirvac Group ( 50% interest Mirvac Old Treasury Trust) DLA Piper King & Wood Mallesons Acquisition $143 million Sidewinder Drilling Union Drilling Vinson & Elkins Davis Polk & Wardwell - Kathleen Ferrell Acquisition $112.5 million Valeant Pharmaceuticals International QLT (Visudyne) Sullivan & Cromwell - Ronald Creamer Acquisition $109.8 million Cypress Semiconductor Corporation Ramtron Davis Polk & Wardwell Acquisition $95 million Meda Jazz Pharmaceuticals Covington & Burling Acquisition Undisclosed Acosta Court Square Capital (Mosaic Sales) Weil, Gotshal & Manges - Marc Silberberg, Mark Schwed, Tara Lancaster Jones Day - Ed Kennedy, Patrick Browne Acquisition Undisclosed Zensho Holdings Long John Silver's (Asia Pacific Food) WongPartnership Nishimura & Asahi TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Revolving Credit Facilities $2.5 billion DIRECTV Holdings Citigroup / Barclays Weil, Gotshal & Manges Davis Polk & Wardwell - Kathleen Ferrell Acquisition Financing $2.12 billion Tempur-Pedic Merrill Lynch Bingham McCutchen Davis Polk & Wardwell - Lucy Farr Secondary Share Offering $1.22 billion Michael Kors Holdings Morgan Stanley / J.P. Morgan / Goldman Sachs Paul, Weiss, Rifkind, Wharton & Garrison / Harney Westwood & Riegels Davis Polk & Wardwell - Harry Ballan Global Offering $1 billion Grupo Aval Goldman Sachs / J.P. Morgan Martínez Neira Abogados / Maples and Calder Simpson Thacher & Bartlett / Gómez-Pinzón Zuleta Abogados Notes Offering $750 million Colombia Telecomunicaciones Credit Suisse / HSBC / J.P. Morgan White & Case / Brigard & Urrutia Abogados Cárdenas & Cárdenas Abogados / Davis Polk & Wardwell - Michael Farber Share Offer $363 million Suncorp Group King & Wood Mallesons Clayton Utz Schedule B debt offering $300 million Korea Finance Corporation Citigroup / Credit Suisse / UBS Cleary Gottlieb Steen & Hamilton / Kim & Chang Davis Polk & Wardwell - John Paton Senior Notes Offering $300 million Torchmark Corporation Merrill Lynch / US Bancorp Investments / Wells Fargo Maynard Cooper & Gale Davis Polk & Wardwell Convertible Senior Notes Offering $125 million XPO Logistics Morgan Stanley / Deutsche Bank / Jefferies & Company Cravath, Swaine & Moore Davis Polk & Wardwell - Po Sit

New Indian tax accounting standards; Netherland to abolish thin capitalisation; Malaysia moots corporate tax cut; Possibility of US carbon tax; Serbia changes VAT; GAP's Indian TP dispute; the future for TP disputes

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Peru Switzerland September 21 2012