Search results for

A report from the Public Accounts Committee of the UK House of Commons has slammed the UK tax authorities' approach to settling disputes with large taxpayers.

Throughout the year, Brazil has been at the centre for conflicting decisions issued by the administrative and judicial courts on transfer pricing matters.

HMRC in the UK has released for the first time extensive statistics about its transfer pricing enquiries, advance pricing agreements (APAs), and mutual agreement procedure (MAP).

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.2 billion United Rentals, Inc. RSC Holdings Sullivan & Cromwell - Ronald Creamer Paul, Weiss, Rifkind, Wharton & Garrison & Debevoise & Plimpton Acquisition $1.1 billion Apollo Management, L.P. Taminco Group Holdings S.à.r.l. Latham & Watkins Davis Polk & Cahill Gordon & Reindel Acquisition $995 million Fujifilm Holdings Corporation SonoSite Shearman & Sterling Fenwick & West - Michael Solomon, Jay Cosel Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Initial Public Offering $1.9 billion New China Life Insurance Company Ltd. China International Capital Corp. Hong Kong Securities Ltd, Goldman Sachs Davis Polk - John Paton & Adam Perry Revolving Credit Facility $1.25 billion V.F. Corporation JPMorgan Chase Bank, N.A. Davis Polk - Mary Conway & Michael Bretholz Cravath, Swaine & Moore Secondary Offering $650 million Banco Santander Chile Santander Investment Securities Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated Davis Polk - Michael Mollerus, Leslie Altus & Changsheng (Eric) Song Notes Offering $350 million IDEX Corporation J.P. Morgan Securities, Merrill Lynch, Pierce, Fenner & Smith Inc & Wells Fargo Securities Latham & Watkins Davis Polk - Neil Barr, Arie Rubenstein & Juelle Gomes Catastrophe Bond Placement $337 million SCOR Aon Benfield Securities Inc & Natixis SA Walkers Global (Ireland) & Dewey & LeBoeuf Wickersham and Taft

The Australian government’s plan to build the country’s reputation as a global financial services centre took a step forward last week when it finalised the country’s investment manager regime (IMR).

Jay Payne has returned to PwC US, as a tax partner in the firm’s Washington Metro practice. He has spent five years as a partner at BDO USA, based in Phoenix, where he was co-chair of BDO’s gaming, hospitality and leisure industry group.

Type of Agreement Country Country Date Signed Double Tax Avoidance Agreement Qatar Portugal December 12 2011 Double Tax Avoidance Agreement Taiwan Switzerland December 13 2011 Double Tax Avoidance Agreement India Australia December 16 2011

Canadian taxpayers should expect more uncertainty when it comes to the country’s general anti-avoidance rule (GAAR) despite last week’s Copthorne ruling, warns a leading lawyer.

India’s Authority for Advance Rulings has clarified the taxability of payments made to a group parent company towards cost allocation for availing support services.

G. Paul Glunt has joined PwC to become a tax principal in the firm’s International Tax Services Practice. He will be based in Los Angeles.