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  • Ernst & Young has announced that David Holtze is the firm’s new global vice chairman for tax.
  • TYPE OF DEAL VALUE ACQUIRER TARGET ADVISER TO ACQUIRER (TAX) ADVISER TO TARGET (TAX) Merger $1.4 billion Justice Holdings / Pershing Square Capital Burger King Worldwide Sullivan & Cromwell - Davis Wang / Greenberg Traurig Kirkland & Ellis Patent Deal $1.1 billion Microsoft AOL Covington & Burling Wachtell, Lipton, Rosen & Katz / Finnegan, Henderson, Farabow, Garrett & Dunner Acquisition $1 billion Facebook Instagram Fenwick & West - Adam Halpern, Natalie Pardo de Zela Orrick Acquisition $950 million Cerberus Capital AT&T (Yellow Pages) Schulte Roth - Alan Waldenberg Sullivan & Cromwell - Andrew Mason Acquisition $221.4 million Witwatersrand Consolidated Gold Resources / Pan African Resources Evander Gold Mines (Harmony Gold Mining) Stikeman Elliott / Eversheds TYPE OF DEAL VALUE ISSUER / BORROWER LEAD MANAGERS / ARRANGERS ADVISER TO ISSUER / BORROWER ADVISER TO LEAD MANAGERS Notes Offering $3 billion Apache Citigroup / Goldman Sachs / J.P. Morgan Bracewell & Giuliani Davis Polk & Wardwell - Michael Farber, Juelle Gomes Notes Offering $2.15 billion Hartford Financial Citigroup / Goldman Sachs Davis Polk & Wardwell - Harry Ballan, Yuliya Epifantseva Cleary Gottlieb Steen & Hamilton Senior Notes Offering $1.5 billion Lloyds TSB Citigroup / Merrill Lynch / Morgan Stanley / Wells Fargo Linklaters / Dundas & Wilson / Davis Polk & Wardwell Allen & Overy Refinancing $1.25 billion Cargill ANZ / Tokyo-Mitsubishi UFJ / BNP Paribas / Deutsche Bank / HSBC / RBS / Standard Chartered WongPartnership Linklaters High-yield Notes Offering $1.1 billion OGX Davis Polk & Wardwell - Po Sit, Ankur Dalal White & Case / Machado Meyer Sendacz Opice Initial Public Offering $490 million Rexnord Merrill Lynch / Goldman Sachs / Credit Suisse / Deutsche Bank / Barclays O’Melveny & Myers Davis Polk & Wardwell - Samuel Dimon, Arie Rubenstein Initial Public Offering $100.1 million Merrimack Pharmaceuticals JP Morgan Wilmer Cutler Pickering Hale and Dorr Davis Polk & Wardwell - Neil Barr, Changsheng Song
  • The Canadian government has proposed changes to section 247 of the Income Tax Act in relation to transactions with foreign related parties, which could have a knock-on effect on companies’ structures involving withholding tax.
  • Despite the continued shift to indirect taxation globally, a majority of businesses still do not have effective global VAT/GST management practices in place, reports Niall Campbell, KPMG’s global head of indirect tax services.
  • The Carbon Reduction Commitment (CRC) has been radically altered since it was devised by the previous UK government and businesses and environmentalists agree it may now be too complex.
  • Last week’s ECOFIN meeting brought yet more bad news for advocates of an EU financial transaction tax (FTT).
  • India’s Authority for Advance Rulings (AAR) has held that a proposed buy-back of shares held by a Mauritian shareholder in an Indian company is a tax avoidance scheme and should be taxable as a dividend.
  • Alvarez & Marsal Taxand has hired James Bartek as managing director in the firm’s New York office.
  • China’s State Administration of Taxation (SAT) is looking to adopt an advance tax ruling (ATR) system in response to increasing pressure on its resources using the traditional audit-based approach.
  • HSBC’s recent victory at the UK First-tier Tax Tribunal means taxpayers should not be charged stamp duty reserve tax (SDRT) on the transfer of shares outside the EU when the transfer is part of a capital raising process.