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  • Clifford Chance in London is losing a partner to Ernst & Young. Mark Persoff will join the big-four firm next Monday as a partner in its EMEIA financial services group.
  • A dispute from China highlights how the country’s tax authorities are applying domestic anti-avoidance rules to deny treaty benefits.
  • A lack of information reporting on many cross-border transactions is a substantial challenge for the Internal Revenue Service (IRS) in the US, says a report from one of the Service’s watchdogs.
  • On June 30 2011, August 9 2011 and October 10 2011, modifications to the Miscellaneous Foreign Trade Rules were published in Mexico's official gazette.
  • Intangible property is an important income generator for many multinational enterprises (MNE), so the OECD consultation with business on the transfer pricing aspects of intangibles was well attended. But, not all taxpayers were in agreement on the issues.
  • Ghana is moving towards implementing a transfer pricing regime with the help of a German development agency.
  • The EU Joint Transfer Pricing Forum (JTPF) will focus on cost sharing agreements (CCA) in service arrangements. Intangible assets, however, will be left out of the discussions.
  • The Australian Taxation Office has announced that it will introduce a new schedule for the 2012 financial year that will affect taxpayers who do business overseas.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $2.2 billion Sony Corp. Of America; Estate of Michael Jackson; Mubadala Dev't Co.; Jynwel Capital; Blackstone; David Geffen EMI Music Publishing (Citigroup) Dewey & LeBoeuf; Weil, Gotshal & Manges; Baker & McKenzie Clifford Chance; Shearman & Sterling; Freshfields Bruckhaus Deringer Alliance termination $1.6 billion Amylin Pharmaceuticals Inc Eli Lilly Skadden, Arps, Slate, Meagher & Flom Acquisition $1.08 billion VeriFone Systems Point International (Nordic Capital) Sullivan & Cromwell - David Passey Seb Enkskilda; White & Case Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior notes offering $2.1 billion Cigna Corporation Morgan Stanley; BofA Merrill Lynch; UBS Investment Bank Davis Polk & Wardwell - Kathleen Ferrell, Jason Chlipala Debevoise & Plimpton Notes offering $1 billion The Korea Development Bank Credit Suisse; Daiwa Capital Markets; Goldman Sachs; KDB Asia; Merrill Lynch; Mizuho Cleary Gottlieb Steen & Hamilton; Hwang Mok Park Davis Polk & Wardwell - John Paton, Sarah Joy Bond offering $300 million Petroleum Geo-Services ASA Barclays Bank; RBS; UBS Limited Shearman & Sterling - Amy Lewis
  • A ruling from India has confirmed that treaty shopping is not taboo and should not warrant enquiry from the authorities.