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  • The new comprehensive double tax agreement (CDTA) between Hong Kong and New Zealand exempts non-property holding companies from capital gains tax on alienation of shares, without any requirement on holding period or percentage of shareholding.
  • A recent transfer pricing dispute in China has reiterated the country’s shift from enforcement and administration towards complex transfer pricing issues and alignment with internationally recognised practices.
  • The Internal Revenue Service (IRS) is expected to expand its Compliance Assurance Programme (CAP) for large business taxpayers.
  • In January 2010, German government abolished property transfer tax in cases of companies undergoing a restructuring.
  • One of the authors of a review of the UK tax system told politicians today that the distinction between the treatment of debt and equity financing was not good for business.
  • Republicans and Democrats agree that the the country’s tax system is in dire need of repair.
  • A US appellate court has waded into the controversy surrounding questions of work product protection and attorney-client privilege in the context of disclosure to the IRS.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $3.5 billion RockTenn Company Smurfit-Stone Wachtell, Lipton, Rosen & Katz - Joshua Holmes Acquisition $1.5 billion Advent International The Priory Group Weil, Gotshal & Manges - Sarah Priestley Deloitte Acquisition $505 million Hubbard Broadcasting, Inc. Bonneville International Corporation Skadden, Arps, Slate, Meagher & Flom - Matthew Rosen, Kirk Wallace Merger Undisclosed SHL PreVisor Weil, Gotshal & Manges - Sarah Priestley KPMG Acquisition Undisclosed Skype Qik Inc. Fenwick & West - Adam Halpern, Larissa Neumann Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Global bond offering $4 billion HSBC Bank plc Shearman & Sterling - James Leslie, Shiu-Kay Hung Senior unsecured notes offering $2.4 billion HCP, Inc. BofA Merrill Lynch, UBS, Wells Fargo Securities, Citi and J.P. Morgan Skadden, Arps, Slate, Meagher & Flom - John Rayis, David Polster Senior notes offering $650 million Labco SAS Shearman & Sterling Bredin Prat - Anne Robert Registered notes offering $400 million ORIX Corporation UBS, Morgan Stanley, Nomura Securities, Citigroup, Merrill Lynch, Pierce, Fenner & Smith Davis Polk & Wardwell - John Paton, Kent Heggerud Simpson Thatcher & Bartlett LLP
  • Stephen Nelson has joined DLA Piper as partner in the firm’s Asia tax team. He will be based in Hong Kong.
  • Michael Fernhoff has joined Proskauer Rose as a partner in the firm’s Los Angeles office.