Search results for

The transfer pricing panel at International Tax Review’s annual Asia Forum in Singapore next month promises to live up to its reputation as one of the most popular panels at the event.

A campaign is building for the introduction of the inter-quartile range and the acceptance of multiple-year data for transfer pricing documentation in India – a country that goes against the global best practice.

By Daniela Camargo, Marta Milewska and Fred Barrett of PwC

The updated members list for the EU Joint Transfer Pricing Forum (JTPF) has been announced. Their mandate is effective from April 1 2011.

Switzerland has pledged a contribution of $5 million to the IMF’s Topical Trust Fund on Tax Policy and Administration.

Law firm McDermott Will & Emery has expanded its international operations by opening a new office in France.

Canada goes to the polls on May 2 when the crucial issue of carbon taxes is expected to loom large in the minds of voters. Opposition parties are in general agreement that cap-and-trade is the best method to use. However, in Australia a lack of consensus on carbon taxes might bring down the government.

China has warned against the use of intermediate Barbados holding companies by foreign companies looking to invest in China.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.7 billion AES Corporation DPL Inc Skadden, Arps, Slate, Meagher & Flom - Cliff Gross Cadwalader, Wickersham & Taft Investment acquisition $291.6 million GS Capital Partners Enstar Group Limited Davis Polk & Wardwell - Kathleen Farrell, Joshua Ruland Drinker Biddle & Reath Acquisition $192 million Eurazeo OFI Private Equity Capital Bredin Prat - Sébastien de Monès, Jean-Florent Mandelbaum Olswang; Mayer Brown Acquisition Undisclosed AloStar Bank of Commerce Nexity Bank, Alabama - FDIC FBR Capital Markets; Davis Polk & Wardwell - Kathleen Ferrell, Yuliya Epifantseva Skadden, Arps, Slate, Meagher & Flom Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) SEC-registered offering $3.31 billion PPL Corporation Credit Suisse Securities; Merrill Lynch, Pierce, Fenner & Smith Inc Simpson, Thacher & Bartlett Davis Polk & Wardwell - Po Sit, Michelle Messer, Niya Tang SEC-registered offering $1.75 billion Royal Bank of Canada Royal Bank of Canada Capital Markets; BNP Paribas; JP Morgan Sullivan & Cromwell; Ogilvy Renault Davis Polk & Wardwell - Harry Ballan, Kerry Price Initial public offering $1.4 billion Arcos Dorados BofA Merrill Lynch; JP Morgan; Morgan Stanley; Itau BBA; Citi Davis Polk & Wardwell - Rachel Kleinberg, Leslie Altus, Catherine Tennant Milbank, Tweed, Hadley & McCloy SEC-registered offering $499 million Cobalt International Energy Inc Morgan Stanley; Credit Suisse; Goldman, Sachs; JP Morgan; Citigroup Davis Polk & Wardwell - Michael Mollerus, Craig Phillips, Rachel Lerner Shearman & Sterling Initial public offering Undisclosed Verallia Bank of America Merrill Lynch; BNP Paribas; JP Morgan Bredin Prat - Sébastien de Monès Allen & Overy

The Fourth Circuit Court of Appeals reminded taxpayers that the US Internal Revenue Service (IRS) has broad authority to review and recalculate tax liability for claimed overpayments, despite the fact that the statute of limitations for the years claimed has run.