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  • Senator Carl Levin has proposed legislation which relieves the US Treasury Department from developing a list of offshore tax havens and instead aims to clarify when foreign financial institutions and US taxpayers would have to report holdings under FATCA.
  • The Delhi Tribunal, in the case of CRM Services, a call centre provider, has passed a relevant ruling for captive IT enabled or business process outsourcing (BPO) service providers.
  • A panel at the National Association of Business Economics Transfer Pricing Symposium, near Washington this week, explored the implications of pre-existing intellectual property (IP) in the IRS’s transfer pricing cases against software companies Xilinx and Veritas.
  • The lack of clarity in part of a new transfer pricing form issued by Malaysia’s tax authorities will create some difficulties and pitfalls for taxpayers.
  • Ernst & Young has announced that Geoff Lloyd, head of dispute resolution at HM Revenue & Customs (HMRC) in the UK, will join the firm in September.
  • Diane Ryan, former national chief of appeals for the IRS, is joining Skadden Arps Slate Meagher & Flom’s Chicago office as of counsel on August 1.
  • Along with the appointment of Greg Wiebe as global head of tax - Canadian partner takes over as KPMG tax chief | International Tax Review – KPMG has also created a new role of global deputy of tax. Ernst Gröbl, head of tax in Germany, as well as head of tax for KPMG Europe and KPMG’s Europe, Middle East, Africa (EMA) region, takes the role. He will focus on major global clients and markets.
  • Next year will herald a widescale period of change for tax in India. It will force tax directors from domestic and international companies to completely reconsider their strategies and to seek efficiencies at all levels of their company's tax affairs.
  • Type of Agreement Country Country Date Signed Double taxation agreement Bahrain Georgia July 18 2011
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $29.1 billion Express Scripts Inc Medco Health Solutions Skadden, Arps, Slate, Meagher & Flom Sullivan & Cromwell - Ron Creamer, King Kai Chu Merger $8 billion Ecolab Inc Nalco Holding Company BofA Merrill Lynch; Baker & McKenzie Acquisition $2.68 billion Grupo de Inversiones Suramericana SA ING Groep NV Sullivan & Cromwell - Ron Creamer Asset swap $790 million Ontario Teachers' Pension Plan Map Freshfields Bruckhaus Deringer - Jean Ng Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Notes offering $2 billion IBM Corporation Deutsche Bank Securities Inc; Goldman, Sachs & Co; HSBC Securities Inc; UBS Securities Inc Davis Polk & Wardwell - Michael Mollerus Revolving credit facility $1 billion The Estée Lauder Companies Inc JPMorgan Chase Bank, NA Weil, Gotshal & Manges Davis Polk & Wardwell - Po Sit, Jason Chlipala Tender offers & senior notes offering $600 million Marsh & McLennan Companies Inc Morgan Stanley & Co; Citigroup Global Markets Inc Davis Polk & Wardwell - Lucy Farr, Patrick Sigmon Willkie Farr & Gallagher Common stock offering $159 million Kodiak Oil & Gas Corporation Credit Suisse Securities; KeyBanc Capital Markets; Wells Fargo Securities Davis Polk & Wardwell - Samuel Dimon, Changsheng Song