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Alyson Rodi and David Watkins, international tax partners, at Deloitte in Australia, discuss the government's tax strategy

Sean Foley The IRS has issued a new directive on section 965 foreign earnings repatriation, LMSB-4-0408-021 (April 21 2008). The directive follows a series of IRS guidance and directives previously issued on the same topic. Generally, the purpose of the directives is to provide guidance to IRS agents on identifying and analysing the issues that arise during the examination of taxpayers that have made an election under section 965.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $6.2 billion Liberty Mutual Group Safeco Debevoise & Plimpton, Seth Rosen Acquisition $5.2 billion Finmeccanica DRS Technologies Arnold & Porter Skadden, Arps, Slate, Meagher & Flom Acquisition $4.1 billion Nordic Capital Fund VII & Avista Capital Partners Bristol-Myers Squibb Cravath, Swaine & Moore, Stephen Gordo, Lauren Angelilli, Luke Facer & Sonia Rodriguez Garcia Merger $2.54 billion The Carlyle Group Booz Allen Hamilton Debevoise & Plimpton, Peter Furci Latham & Watkins Acquisition ?1.6 billion ($2.5 billion) freenet Debitel Group Hengeler Mueller, Martin Klein Ernst & Young Acquisition £1.1 billion ($2.1 billion) Best Buy The Carphone Warehouse Freshfields Bruckhaus Deringer, Richard Ballard & Jenny Doak Merger $1 billion Planeta Editis Garrigues, Albert Collado & Arsene, Denis Andres Willkie Farr & Gallagher, Marie-Hélène Raffin Acquisition $826 million Cosan SA Industria E Comercio Esso Brasileira de Petroleo White & Case, David Dreier & Gregg Benson Merger $800 million United Online FTD Group Skadden, Arps, Slate, Meagher & Flom, Moshe Kushman Latham & Watkins, Joseph Kronsnoble Acquisition $650 million Cablevision Systems Newsday (owned by Tribune) Hughes Hubbard & Reed, Andrew Braiterman & Damon Rowe Acquisition $544 million Macquarie Infrastructure Investment Management& The Goldman Sachs Group Waste Industries USA Weil, Gotshal & Manges, Kim Blanchard Acquisition $425 million Cobham Defense Electronic Systems Tyco Electronics Davis Polk & Wardwell, Rachel Kleinberg, Neil Barr Acquisition $268 million Blue Coat Systems Packeteer Davis Polk & Wardwell, Rachel Kleinberg & Ryan LaRosa DLA Piper Acquisition $211.7 million Finisar Optium DLA Piper Goodwin Procter, Colette Goodman Acquisition £65 million ($128 million) Babcock International Group Weir Strachan & Henshaw Ashurst, Richard Palmer & Kate Marten Acquisition £40.4 million ($79.6 million) Elementis Deuchem O'Melveny & Myers, Larry Sussman Acquisition $23 million Mars The Wrigley Company Skadden, Arps, Slate, Meagher & Flom, Max Miller Acquisition Undisclosed Symantec Corporation AppStream Fenwick & West, Ron Schrotenboer Acquisition Undisclosed Leucadia National Corporation Jefferies Group Jefferies Group Acquisition Undisclosed iCrossing 3GNet Baker & McKenzie, Marc Scheunemann Acquisition Undisclosed IBM FilesX Cravath Swaine & Moore, Andrew Needham, J. Leonard Teti & Jonathan Katz Acquisition Undisclosed IBM Diligent Technologies Cravath Swaine & Moore, Andrew Needham & Anne Kim Choi Acquisition Undisclosed IFCO Systems STECO Group Weil, Gotshal & Manges, Kian Tauser Acquisition Undisclosed Platinum Equity Covad Communications Bingham McCutchen Fenwick & West, Tim Fitzgibbon Acquisition Undisclosed IBM InfoDyne Cravath Swaine & Moore, J. Leonard Teti & Luke Facer Acquisition Undisclosed Sika Valspar Baker & McKenzie, Ross MacDonald Acquisition Undisclosed Sika ICS Garland Baker & McKenzie, Ross MacDonald Acquisition Undisclosed Genesee & Wyoming CAGY Industries Simpson Thacher, Rob Holo & Jonathan Goldstein Acquisition Undisclosed Comcast Plaxo Davis Polk & Wardwell, Rachel Kleinberg Type of Deal Value Issuer/borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Financing $740 million Topaz Holdings Morgan Stanley, Dexia Credit Local, ING Capital & Natixis Shearman & Sterling, Mitchell Menaker & Amy Lewis Promote your tax practice, send deal information to Joanna Faith at jfaith@euromoneyplc.com; +44 207 779 8359

NERA Economic Consulting, an independent international firm of economists, has appointed Graham Poole as head of its UK transfer pricing group. He joins as an associate director. Poole is a specialist in advanced pricing agreements and transfer pricing for intangibles. Poole has been active in transfer pricing for 14 years in the consumer goods, professional services, automotives, oil and gas, shipping, high-tech manufacturing, software and financial services sectors.

Richard Collier-Keywood Richard Collier-Keywood, the firm's UK head of tax, will become managing partner of Pricewaterhouse-Coopers in the UK on July 1.

Glen Atchison, head of tax at Harbottle & Lewis in London has been appointed managing partner of the firm. He replaces Lawrence Abramson, who has been the firm's managing partner since 2005. Atchison has been head of the tax practice since 1998 and specialises in corporate tax, personal tax and strategic tax matters.

Charities suffering from tax avoidance Two leading charities have attacked international companies for their tax minimisation policies. Christian Aid and Action Aid published separate reports in May criticising company tax strategies.

Nélio Weiss Philippe Jeffrey There has be-en recently growing interest on the part of the US to negotiate and conclude a treaty to avoid double taxation (DTT) with Brazil. In this regard, the US authorities have declared on a number of occasions that a double taxation agreement with Brazil is part of the country's economic and political strategy in relation to Latin America, considering that Brazil is today the largest economy in the region. Several large companies in the two countries have also shown interest in furthering negotiations toward the conclusion of a DTT.

Sabine Graziosi On May 8 2008 Advocate General (AG) Sharpston issued her opinion in the Cobelfret case. This is one of the three pending cases regarding the compatibility of the Belgian participation exemption regime with the EU parent subsidiary directive (90/435/CEE). The present case only concerns dividends received from subsidiaries established in other EU member states, while the other cases also concern dividends received from Belgian subsidiaries and non-EU subsidiaries and the question whether the Belgian regime is compliant with respectively the directive and the free movement of capital.

Neil Wilson One of the key ingredients to any successful tax strategy is achieving and sustaining a competitive tax rate. As a result, a company's tax rate is increasingly found on boardroom agendas. On the one hand, taxes are a significant cost that needs to be controlled and managed to create shareholder value and maximise earnings per share. On the other hand, the amount of tax paid by large corporations is coming under increasing scrutiny and public debate, and companies need to consider their reputation with a wider group of stakeholders.