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McDermott Will & Emery has announced the appointments of Cym Lowell and Mark Martin as part of a seven-person, full-service transfer pricing team in Texas, both from from Gardere Wynne Sewell.

In the latest Senate Finance Committee hearing into US tax reform, the impact of reform on energy policy was assessed, with committee chairman Max Baucus saying it provides the energy sector with an opportunity to make real progress in securing future energy supply while also simplifying the tax code.

The IRS and Treasury have released new rules that make it harder for US companies to relocate to low-tax jurisdictions.

Presidential candidate Mitt Romney used his speech at a Business Roundtable event in Washington, DC, last week to call for an end to the tax levied when US corporations repatriate their foreign profits.

Marlies de Ruiter, head of the tax treaty, transfer pricing and financial transactions division at the OECD, agrees with tax justice activists that the transfer pricing guidelines could work better, but she remains loyal to the arm’s-length principle (ALP).

Insight into why Finland wants to introduce a financial transaction tax, why HMRC is in danger of discrediting UK taxpayer settlements, and how to get faster dispute resolution at the Tax Court of Canada were just three articles that appeared on ITR Premium last week.

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement (Protocol) Luxembourg Poland June 7 2012 Double Taxation Avoidance Agreement Liechtenstein UK June 11 2012

The aim of the new Germany-Luxembourg double tax treaty (DTT) is to replace the one signed in 1958, and follows the structure and, for the most part, the content of the OECD Model Tax Convention.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $2.1 billion Hong Kong Exchanges and Clearing London Metal Exchange Allen & Overy Freshfields Bruckhaus Deringer Acquisition $1 billion Apax / JMI Paradigm Kirkland & Ellis Skadden, Arps, Slate, Meagher & Flom Acquisition $555 million Upsher-Smith Laboratories Proximagen Group Skadden, Arps, Slate, Meagher & Flom - Tim Sanders Reed Smith - Caspar Fox Acquisition $386 million Lion Little World Beverages King & Wood Mallesons - Judy Sullivan Freehills Acquisition $382 million Unibail-Rodamco Perella Weinberg (mfi) Hengeler Mueller Merger U.S. Silver Corporation RX Gold & Silver Stikeman Elliott - Dean Kraus, Francesco Gucciardo Davies Ward Phillips & Vineberg Acquisition Undisclosed América Móvil Telekom Austria Wachtell, Lipton, Rosen, & Katz / Wolf Theiss Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $600 million Bunge Citigroup / J.P. Morgan / Morgan Stanley / BNP Paribas Davis Polk & Wardwell - Harry Ballan Senior Notes Offering $400 million PPL Capital Funding BNP Paribas / Goldman, Sachs / J.P. Morgan / UBS Davis Polk & Wardwell - Samuel Dimon Sullivan & Cromwell Intercompany Financing $181 million Singapore Press Holdings Seletar Mall WongPartnership Lee & Lee Syndicated Loan $125 million China Aviation Oil ABN AMRO / Australia and New Zealand Banking Group / Bank of Communications / Crédit Agricole / United Overseas WongPartnership Rajah & Tann

Multinational agricultural company Bunge estimates up to €1 billion ($1.26 billion) a year is being lost in Hungary because of VAT fraud on food products, and the reaction of the tax authorities could give compliant companies and multinationals a headache.