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  • HM Revenue & Customs (HMRC) in the UK has dramatically increased the penalty regime for taxpayers that hide income offshore.
  • The Australian Tax Office has released a tax ruling today on business restructuring.
  • The UK bank levy introduced in January was supposed to be eased in with a rate of 0.05% for the first year of implementation.
  • The Internal Revenue Service (IRS) has announced a second round of its voluntary disclosure programme, which encourages recalcitrant taxpayers to come forward and reveal hidden offshore assets to the tax authorities.
  • The UK Treasury would earn £200 million ($322 million) over five years from tax relief for the UK video games industry.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition/Joint Venture $37 billion Comcast Corp. NBC Universal Inc. Davis Polk & Wardwell Weil Gotshal & Manges; Arnold & Porter Acquisition $7.1 billion Alpha Natural Resources Massey Energy Cleary, Gottlieb, Steen & Hamilton - James Duncan Cravath, Swaine & Moore - Andrew Needham Acquisition $1.9 billion Newmont Mining Corporation Fronteer Gold Inc. Wachtell, Lipton, Rosen & Katz - Deborah Paul, Michael Sabbah Davies, Ward, Phillips & Vineberg Acquisition $1.4 billion Intel Corp. Infineon Technologies AG Hengeler Mueller - Martin Klein, Lars Kloster Gleiss Lutz - Alexander Werder, Stefan Mayer Merger $548 million Berkshire Hathaway Inc. Wesco Financial Corp. Munger, Tolles & Olson Skadden, Arps, Slate, Meagher & Flom - Michael Beinus Acquisition $200 million Advent International Towergate Partnership Weil, Gotshal & Manges - Ian Hamilton, Sarah Priestley DLA Piper - Mel Sims Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Initial Public Offering $900 million BankUnited Inc Morgan Stanley & Co; Merrill Lynch, Pierce, Fenner & Smith Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - William Weigel, Andrew Teruo Hayashi Initial Public Offering $314 million Adecoagro S.A. Credit Suisse Securities; Morgan Stanley & Co; Itau BBA USA; Deutsche Bank Securities Millbank, Tweed, Hadley & McCloy Davis Polk & Wardwell - Kathleen Ferrell, Michelle Messer, Kerry Price Initial Public Offering $250 million Blackstone/GSO Long-Short Credit Income Fund Wells Fargo Securities; Merrill Lynch, Pierce, Fenner & Smith; UBS Securities Simpson Thatcher & Bartlett Davis Polk & Wardwell - Mary Conway, Adam Perry SEC-registered offering $250 million Steelcase Inc. J.P. Morgan Securities; Merrill Lynch, Pierce Fenner & Smith Skadden, Arps, Slate, Meagher & Flom Davis Polk & Wardwell - Sam Dimon, Changsheng (Eric) Song Registered Public Offering $230 million Savient Pharmaceuticals Inc. J.P. Morgan Securities Wilmer Cutler Pickering Hale & Dorr Davis Polk & Wardwell - Michael Farber, Brian Radigan
  • Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement India Norway February 2 2011 Double Taxation Avoidance Agreement Bahrain Isle of Man February 3 2011 Tax Information Exchange Agreement India Isle of Man February 8 2011
  • After the OECD’s release of a scoping document, on its new project on the transfer pricing aspects of intangibles, Caroline Silberztein, head of the transfer pricing unit at the OECD Centre for Tax Policy and Administration, talks to Salman Shaheen of TP Week about the issues to be addressed, what areas could not be covered and what form the consultation process will take now.
  • Joclyn Pampel has been elected as a partner in the tax practice group in the firm’s Chicago office.
  • The Senate Budget Committee heard testimony from four tax experts last Wednesday in a two-hour session that could be summed up in a few words: the US needs a VAT.