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Shawn O‘Brien has joined Mayer Brown’s tax controversy practice in Houston, as a partner.

Several organisations, including the Tax Executives Institute (TEI) have written to Indian prime minister Manmohan Singh and finance minister Pranab Mukherjee, outlining their objections to the government’s decision to retrospectively amend the tax code. Here, the TEI expands on why it has objected.

A new report from Citizens for Tax Justice indicates 26 Fortune 500 companies such as Boeing, GE, Verizon and Duke Energy, paid no US federal income taxes in the last four years. While statistics like this will shock some, the biggest impact of this may be the push for tax reform.

The Global Forum on Transparency and Exchange of Information released peer reviews of 11 jurisdictions this month, assessing their progress on transparency and exchange of information, but the Tax Justice Network (TJN) and International Chamber of Commerce (ICC) are calling for improvements to the process.

The United Arab Emirates (UAE) does not intend to introduce new taxes on companies until 2013 at the earliest, despite conducting studies surrounding a proposal to tax companies operating in the region.

The Delhi High Court has ruled that the transfer pricing officer (TPO) cannot disallow royalties just because the company paying them is incurring losses.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $10.8 billion GDF Suez International Power Rothschild & Ondra Nomura Acquisition $1 billion Penn Virginia Resource Marcellus Shale Midstream Pipeline Vinson & Elkins / Latham & Watkins - Tim Fenn, Cheryl Coe, Victoria Louie Thompson & Knight Merger $625 million Danaher X-Rite Kirkland & Ellis Winston & Strawn Acquisition $380 million The Gores Group Touch Solutions (TE Connectivity) Davis Polk & Wardwell Acquisition $349 million India Hospitality Corp Adelie Foods Group Grant Thornton / Travers Smith Acquisition $315 million Amgen KAI Pharmaceuticals Sullivan & Cromwell Latham & Watkins Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Notes Offering $2 billion Vivendi J.P. Morgan / Merrill Lynch / Citigroup Davis Polk & Wardwell - John Paton, Sarah Joy SEC-Registered Notes Offering $500 million ORIX Morgan Stanley / Deutsche Bank / Merrill Lynch Mitsui / Davis Polk & Wardwell - John Paton, Sarah Joy Simpson Thacher & Bartlett

Ireland's Finance Bill 2012 proposes a number of welcome improvements to Ireland's research and development (R&D) tax credit regime.

The question regarding to what extent a permanent establishment (PE) or a branch should be treated as a separate entity from its head office and the question of which is the tax treatment applicable to transactions performed between them, has been a discussed issue over which the Chilean IRS has not sustained a clear criteria.

Since low value consignment relief (LVCR) was removed from Channel Islands imports in last month’s UK budget, companies have been looking for new loopholes. Sensible businesses would be wise not to touch them.