Search results for

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $17.7 billion Delta Air Lines Northwest Airlines Wachtell, Lipton, Rosen & Katz Simpson Thacher & Bartlett, Steve Todrys & Amie Broder Acquisition €5.6 billion ($8.9 billion) Pernod Ricard Vin & Sprit Group Debevoise & Plimpton, Gary Friedman Davis Polk & Wardwell, Kathleen Ferrell & Joanna Mork Merger $2.25 billion West Siberian Resources Alliance Oil Baker & McKenzie Clifford Chance Acquisition $1.35 billion Blockbuster Circuit City Stores Sullivan & Cromwell, Ronald Creamer Wachtell, Lipton, Rosen & Katz, T Eiko Stange Acquisition £1.15 billion ($2.3 billion) Tata Jaguar and Land Rover (owned by Ford) Blake, Cassels & Graydon, Kathleen Penny Acquisition £750 million ($1.5 billion) Mechel OAO Oriel Resources Allen & Overy Norton Rose, Dominic Stuttaford Acquisition $709 million Patriot Coal Magnum Coal Davis Polk & Wardwell, Kathleen Ferrell & Craig Phillips Acquisition $475 million Gores Group Gilat Satellite Networks Weil, Gotshal & Manges, Greg Burns Carter Ledyard & Milburn Acquisition $250 million L-1 Identity Solutions Digimarc Corporation Weil, Gotshal & Manges, Scott Sontag Perkins Coie, Jeff Van Hove & Lisa McGimpsey Acquisition $240 million Konica Minolta Business Solutions Danka Office Imaging Company Milbank, Tweed, Hadley & McCloy, Paul Wessel Acquisition £120 million ($236 million) 3i Group Hyperion Insurance Group Taylor Wessing, Anthony Metcalfe-Gibson & Ann Casey Acquisition £35 million Barclays Bank Discover Financial Services Freshfields Bruckhaus Deringer, David Taylor, Jenny Doak & Susanna Pirie Acquisition £25 million ($49 million) AMEC Rider Hunt International Berwin Leighton Paisner, Sarah Gatehouse Acquisition £25 million ($49 million) 3i Infrastructure The Alma Mater Fund Slaughter and May, Steve Edge Acquisition Undisclosed Ramsay Heath Care BMI Nottingham Hospital Lovells, Kevin Ashman Disposal Undisclosed Wellness Foods Dorset Cereals Howard Kennedy Travers Smith, Russell Warren Acquisition Undisclosed AXA Group SBJ Group SJ Berwin, Gareth Amdor & Anna Downey Acquisition Undisclosed Hewitt Associates New Bridge Street Consultants Debevoise & Plimpton, Dawn Bhoma Berwin Leighton Paisner Acquisition Undisclosed U.S. Bank National Association Mellon 1st Business Bank Wachtell, Lipton, Rosen & Katz, Joshua Holmes & Lauren Cooper Acquisition Undisclosed Milestone Capital Partners Coffee Nation Osborne Clarke, Andree Power Ashurst, Simon Swann Acquisition Undisclosed Novartis Nestle's stake in Alcon Cravath, Swaine & Moore, Michael Schler & Dana Frenkel Acquisition Undisclosed AAC Capital Partners James Dewhurst CMS Cameron McKenna, Aaron Fairhurst, PricewaterhouseCoopers, Paul Wood Lovells, Andy Treavett Acquisition Undisclosed Deka 50 Finsbury Square Herbert Smith, Andrew Prowse Simmons & Simmons Acquisition Undisclosed Tricor Group Aldbridge Group's Corporate Services practice Mayer Brown Acquisition Undisclosed Roche Piramed Freshfields Bruckhaus Deringer, Colin Hargeaves Morrison & Foerster, Trevor James Acquisition Undisclosed Miles 33 Net-Linx Publishing Solutions Osborne Clarke, Andree Power Type of Deal Value Issuer/borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Flotation $1.1 billion Zhaikmunai LP ING Bank White & Case Skadden, Arps, Slate, Meagher and Flom, Sally Thurston, Chris Hutley, Sanjay Mehta & Chase Wink Offering $1 billion Virgin Media Goldman Sachs Fried Frank, Keith Featherstone, Laura Levy IPO $500 million Seven Bank Nomura Securities, Morgan Stanley & Nikko Citigroup Simpson Thacher & Bartlett, Robert Holo IPO $19.7 billion Visa JP Morgan White & Case, Bruce Davis & Sang Ji Placing £10 million ($19.7 million) Plasmon Kaupthing Singer & Friedlander Capital Markets SJ Berwin Travers Smith Promote your tax practice send deal information to Joanna Faith at jfaith@euromoneyplc.com; +44 207 779 8359

By Ralph Cunningham

Jane Dodd The UK's offshore funds regime is designed to prevent income being rolled up offshore and converted into capital. Investors disposing of a material interest in an offshore fund are taxed as if the receipt is an income receipt rather than capital. A material interest is, broadly, an interest which the investor can expect to realise within seven years. The UK's offshore funds regime does not apply to funds which distribute at least 85% of their income. These are known as distributing funds.

By Bob Reynolds

On January 4 2008 the ministry of finance issued a tax ruling stipulating that a merged company would realise capital gains on deemed disposal of fixed assets arising from merger under purchase method if the merger was concluded on or after January 1 2008.

KR Sekar of Deloitte explores the diversity in legal interpretations of beneficial ownership

By Bob Reynolds

Akio Takisaki The 2008 tax reform plan is now under consideration by the Diet. The summary below explains the major proposed changes regarding national corporate income tax.

Massimo Agostini Italy is implementing directive 2005/56/EC, dated October 26 2005 (the merger directive) trough a draft legislative decree passed by the Italian government on February 27 2008 in execution of delegation Law no 13 dated February 6 2007, which is to be published in the Official Gazette (the merger decree). Italy has already implemented the tax merger directive (directive 90/434/EEC, dated July 23 1990, as lastly amended by directive 2005/19/EC, dated February 17 2005) through legislative decree no. 199, dated November 6 2007.

Markus Anderruethi Citizens of the canton of Obwalden approved on December 16 2007 a tax law revision further lowering the tax burden on businesses and individuals. The revision strengthens the 2005 tax reform designed to enhance Obwalden's attractiveness as a business and residential location. This latest revision was originally planned for 2009, but was moved forward following this year's Supreme Court decision against Obwalden's degressive tax regime. It entered into force from January 1 2008.