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  • Hong Kong today introduced significant changes to its intellectual property (IP) regime that will promote wider application of IP and encourage the development of creative industries.
  • The first ever Tax Disputes Week tax table shows that McDermott Will & Emery and Mayer Brown each have a significant tax case pending before US appellate courts.
  • Complainant Case or Action Adviser to complainant Respondent Court Next scheduled activity Agilent Technologies Mexico Administrativ Appeal of 2003 Tax Audit of import declaration Baker McKenzie Guillermo Villaseñor and Roberto Cardona Tax Service Administration Legal Section of the Ministry of Treasury Aracruz Celulose Right to use IPI credit premium Bichara Barata Costa & Rocha Advogados Luiz Gustavo Bichara and Luciana Martins de Oliveira Brazilian National Treasury Brazil's Superior Tribunal of Justice Aracruz Celulose Case before administrative tribunal to maintain tax benefits Bichara Barata Costa & Rocha Advogados Luiz Gustavo Bichara and Luciana Martins de Oliveira Brazilian National Treasury Federal Tax Appeal Council Auto Americano s/a Distribuidor de Pecas Case about exclusion of VAT from taxable basis Brazilian Federal Government Federal Supreme Court of Brazil Judgment suspended due to filing of constitutionality statemante action Brascan Quimicos e Soldas Ltd. Contesting tax assessment and penalties imposed by tax authorities Bichara Barata Costa & Rocha Advogados Luiz Gustavo Bichara and Luciana Martins de Oliveira Brazilian National Treasury Federal Tax Secretariat Awaiting 1st level administrative decision Caiua Servicos de Electricidade Contesting constitutionality of collecting VAT on leasing transactions State of Sao Paulo Federal Supreme Court of Brazil Judgment suspended due to request of case records for examination Global Vessels Mexico Withholding on chartering Baker McKenzie Guillermo Villaseñor and Roberto Cardona Mexican Tax Authorities Federal Tax Court of Mexico City Grupo Jumex, SA de CV Case over whether holding company should add losses to consolidated tax profit Basham Ringe & Correa Luis Ortiz Hidalgo and Ramiro Hernandez Mexican Tax Administration Service Mexican Federal Tax and Administrative Tribunal Heerema Marine Contractors Mexico Administrative Appeal of 2006 tax assessment for deductions of a Mexican branch Baker McKenzie Guillermo Villaseñor and Roberto Cardona Tax Audit Administration Federal Tax Court of Mexico City Inlogs Logistica Ltda, Incasa SA, A Guerra SA Implementos Rodoviarios Proceeding on applicability of tax immunity to export revenues Brazilian Federal Government Federal Supreme Court of Brazil Judgment suspended due to request of case records for examination Marcopolo S/A (acting as respondent) Administrative Proceedings Brazilian Federal Revenue Service Federal Administrative Council of Tax Appeals (Brazil) Taxpayer's appeal pending National Industry Confederation Proceeding challenging constitutionality of Brazilian CFC rules Brazilian Federal Government Federal Supreme Court of Brazil National Trade Confederation and National Industry Confederation Challenging constitutionality of the right of tax authorities to access taxpayer's bank information Brazilian Federal Government Federal Supreme Court of Brazil Nissan Mexicana, SA de CV Improper deductions for damages compensation Basham Ringe & Correa Luis Ortiz Hidalgo and Alejandro Arzate Mexican Tax Administration Service Mexican Supreme Court of Justice Judgment expected in spring 2011 Parati Petroleo Ltda Refund of difference in overpaid VAT State of Minas Gerais (Brazil) Federal Supreme Court of Brazil Judgment of the Full Session has been suspended Reckitt Benckiser Mexico Usufruct of Shares and Annulment Petition Baker McKenzie Guillermo Villaseñor and Roberto Cardona International Tax Audit Administration Federal Tax Court of Mexico City SC Johnson & Johnson, SA de CV Rejection of deduction for payment made by non-resident Basham Ringe & Correa Luis Ortiz Hidalgo and Alejandro Arzate Mexican Tax Administration Service First Circuit Collegiate Court on Administrative Matters Judgment expected in 2011 Sony DADC Mexico Tax Audit for the Fiscal Year 2002 (Recharacterisation of Dividends Baker McKenzie Guillermo Villaseñor and Roberto Cardona Mexican Local Tax Administration Mexican Federal Tax Court Sony DADC Mexico Administrative Appeal of 2003 tax assessment for royalty payments Baker McKenzie Guillermo Villaseñor and Roberto Cardona International Tax Audit Administration Legal Section of the Ministry of Treasury WDC Mexico Litigation against 2003 assessment Baker McKenzie Guillermo Villaseñor and Roberto Cardona Tax Audit Administration Federal Tax Court of Mexico City
  • A long-running area of dispute in India has come to an end with the Supreme Court upholding the powers of parliament to enact laws with extra-territorial jurisdiction.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $535 million The Renco Group Severstal North America Skadden, Arps, Slate, Meagher & Flom Acquisition Undisclosed Barclaycard Egg Banking plc Freshfields Bruckhaus Deringer - Sarah Perfect Acquisition Undisclosed Europeenne de Participations Industrielles SAS (EPI) Remy Cointreau Bredin Prat - Yves Rutchmann, Julien Gayral, Chloe Delion Linklaters - Thierry Riguet, Laetitia Peyrat Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Notes offering $1.7 billion McKesson Corporation JP Morgan Securities; Merrill Lynch, Pierce, Fenner & Smith Davis Polk & Wardwell - Michael Mollerus, Niya Tang SEC registered debt offering $1 billion Juniper Networks Barclays Capital; Citigroup Global Markets; Morgan Stanley & Co Wilson Sonsini Goodrich & Rosati Davis Polk & Wardwell - Rachael Kleinberg, Ryan LaRosa IPO $42 million Zuoan Fashion Limited Cowen & Company; RBC Capital Markets; Samsung Securities; Janney Montgomery Scott Davis Polk & Wardwell - John Paton, Alon Gurfinkel O'Melveny & Myers
  • Thomas Henry has joined PwC's global incentives practice in New York as tax partner.
  • The European Parliament today voted to approve MEP Anni Podimata’s through report, which recommends introducing a global financial transactions tax (FTT) which could be used to fund future bailouts.
  • They say that the bigger they come the harder they fall. Few could have expected quite how hard Nortel would fall, however, or the unique cross-border tax issues the resulting administration of the group in Europe would cause.
  • Type of Agreement Country Country Date Signed Tax Information Exchange Agreement Isle of Man Poland March 7 2011 DTA Isle of Man Poland March 7 2011
  • Paul DiSangro will rejoin Mayer Brown’s tax controversy practice in Palo Alto , California on March 7.