Search results for

By Daniel Rybnik, of EnterPricing, Buenos Aires

Todd Miller and Michael Friedman of McMillan in Toronto, Canada, explain the documentation rules in Canada and how recent treaty developments and court decisions will affect taxpayers.

The UN’s proposed plans for a global carbon tax and FTT, why the ECJ has raised the threshold for denying EU companies VAT deductions, and how the UK rate cut has changed tax accounting procedures were just three articles that appeared on ITR Premium last week.

The Argentine government has terminated its tax treaties with Chile and Spain. These treaty terminations are significant and may impact existing cross-border structures and/or planning by multinationals with operations or investments in Argentina involving Chile or Spain.

The final SEC staff report on the use of International Financial Reporting Standards (IFRS) within the US does not include a recommendation for when and how they should be introduced, disappointing the body charged with enabling the convergence of accounting standards globally.

As part of the 2012 Tax Reform, Japan adopted earnings-stripping provisions under which a corporation's deduction for net interest expense paid to a related party will be limited to 50% of adjusted income effective for tax years beginning on or after April 1 2013.

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Canada Colombia Entered into force June 12 2012 Tax Information Exchange Agreement China San Marino July 9 2012

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.92 billion Dentsu Aegis Linklaters / Baker & McKenzie Slaughter and May / Sullivan & Cromwell Acquisition $4.9 billion WellPoint Amerigroup Linklaters Skadden, Arps, Slate, Meagher & Flom Acquisition $4.1 billion Intel ASML Gibson, Dunn & Crutcher / Morrison & Foerster De Brauw Blackstone Westbroek / Skadden, Arps, Slate, Meagher & Flom Acquisition $3.03 billion Walt Disney / Hearst NBC Universal Media (A&E Television Networks) Davis Polk & Wardwell - Neil Barr Acquisition $1.55 billion Campbell Soup Bolthouse Farms Davis Polk & Wardwell - Harry Ballan, Arie Rubenstein Kirkland & Ellis Acquisition $620 million Thomson Reuters FX Alliance Fried, Frank, Harris, Shriver & Jacobson / Shearman & Sterling Kirkland & Ellis Acquisition $207 million AptarGroup Stelmi Bredin Prat - Pierre-Henri Durand / Hengeler Mueller / Uría Menéndez CMS Bureau Francis Lefebvre Acquisition $173 million PEYTO Exploration & Development Open Range Energy Stikeman Elliott Acquisition $98 million Madison Dearborn Partners QuickPlay Media Kirkland & Ellis Stikeman Elliott Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Hybrid Project Financing $885 million Línea Amarilla BNP Paribas / Citibank Davis Polk & Wardwell - Harry Ballan Mayer Brown / Rubio Leguía Normand / Xavier Bragança Advogados / SNR Denton / Miranda & Amado Abogados Subordinated Notes Offer $512 million Westpac ANZ Securities / Deutsche Bank / J.P. Morgan / UBS / Westpac Institutional King & Wood Mallesons - Richard Snowden Freehills Notes Reopening $500 million Korea Development Bank Barclays / Citigroup / KDB Asia / Standard Chartered / UBS Cleary Gottlieb Steen & Hamilton Davis Polk & Wardwell Guaranteed Bonds Offering $235 million AVIC International BOCI Asia / Morgan Stanley Linklaters / Beijing Sunlight / Conyers Dill & Pearman Davis Polk & Wardwell - Alon Gurfinkel / Jingtian & Gongcheng

On June 5 2012 the Italian Tax Administration released a Circular Letter regarding international tax disputes and clarifying the MAP process.

By Davide Bergami, of Ernst & Young