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Nélio Weiss Philippe Jeffrey The Brazilian senate rejected on December 13 2007, the proposal to extend up to December 2011 the application of the temporary contribution on financial activities (CPMF), which consequently expired on December 31 2007.

Stephen Nelson The implementing regulations of the PRC Enterprise Income Tax Law (the regulations) finally were promulgated on December 11 2007 and entered into effect on January 1 2008 together with the tax law. The PRC State Council has also released a notice dated December 26 2007 (notice) on grandfathering arrangements for foreign-invested enterprises (FIEs) that are entitled to lower tax rates and tax holidays. This article addresses some of the key areas that are addressed by the regulations and the notice.

Andrés Edelstein Ignacio Rodríguez The Argentine tax authorities (AFIP) have been focusing, over the past few years, on the deduction of interest and foreign exchange losses arising from loans granted by foreign related lenders.

Veerle Coussee Wim De Pelsmaeker In a recent administrative decision, the VAT administration altered its point of view in respect of VAT deduction on rented passenger cars. This finally puts an end to the years of legal controversy concerning the prohibition on the full deduction of VAT on rental or replacement cars by companies other than mere leasing companies.

The Internal Revenue Service has identified four necessary components of an intermediary transaction tax shelter (ITTS). An ITTS is a loophole which attempts to avoid corporate income tax from the sale of assets. The components are: a target corporation directly or indirectly owns assets and has insufficient tax benefits to eliminate or offset tax in whole or in part; at least 50% of the target corporation's stock is disposed of by its shareholders, other than in a liquidation transaction within a 12 month period; within the 12 months before or after the shareholders disposes of at least 50% of the target corporation's stock, its assets are sold to one or more buyers; and the target corporation's built-in tax is purportedly offset, avoided or not paid.

Stephane Taieb, of Baker & McKenzie in Paris, says the proposed reform is welcome but could go further

William Hawkins The Board of The Coca-Cola Company has elected William Hawkins as vice president of the company and appointed him general tax counsel. Hawkins has worked in the Company's Office of General Tax Counsel since 1998 and will now lead the tax policy and strategy team.

CRA International, the US-based transfer pricing specialist, has announced substantial transfer pricing growth and appointed a series of new directors.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Disposal $14 billion Lafarge Cement Group Cement arm of Orascom Construction & Industries (OCI) KPMG, Abdelhamid Attalla Acquisition $8.5 billion Oracle BEA Systems Latham & Watkins Wachtell, Lipton, Rosen & Katz, T Eiko Stange, Michael Sabbah Acquisition $4 billion Bank of America Countrywide Financial Cleary Gottlieb Steen & Hamilton, Leslie Samuels, William McRae, Corey Goodman Wachtell, Lipton, Rosen & Katz, Joshua Holmes Acquisition £1.78 billion ($3.5 billion) North West Electricity Networks United Utilities Electricity Ashurst, Nicholas Gardner Slaughter and May, Graham Airs, Edward Denny Acquisition $3 billion Turbo Alpha Abbot Group Slaughter and May, Gareth Miles, Timothy Woodthorpe Pinsent Masons Acquisition $2.7 billion Rank Group, New Zealand Alcoa (Flexible Packaging, Closure Systems International, Consumer Products & Reynolds Food Packaging divisions) Debevoise & Plimpton, Michael Bolotin (US) Cravath, Swaine & Moore, Stephen Gordon, Christian Brause Acquisition $2.65 billion CommScope Andrew Corporation Fried Frank Harris Shriver & Jacobson, Joel Scharfstein Mayer, Brown, Thomas Bottomlee, Denise Lopez Acquisition $2.65 billion Agrium UAP Holding Blake, Cassels & Graydon Wachtell, Lipton, Rosen & Katz, Jodi Schwartz Acquisition $1.3 billion Bain Capital Partners Bright Horizons Family Solutions Ropes Gray Shearman & Sterling, Bass, Berry & Sims, Curtis Fisher Acquisition $1.3 billion Blackstone Group & Wellspring Capital Performance Food Group Simpson, Thacher & Bartlett Bass, Berry & Sims Acquisition $1 billion Sun Microsystems MySQL Wilson, Sonsini, Goodrich & Rosati, Ivan Humphreys & Elaine Marshall Fenwick & West, Ron Schrotenboer;Timothy Fitzgibbon Acquisition $970 million Credit Suisse Asset Management Norwich Union Trust Linklaters, Jonathan Evans, James Morgan In house counsel Acquisition $930 million Blackstone Group GSO Capital Partners Simpson Thacher & Bartlett, John Hart, Kurt Dudas, Rian Balfour, Deloitte & Touche, James DeJesus, Charles Schramm Schulte Roth & Zabel, Philippe Benedict, Andre Weiss, Steve Fredman Acquisition $850 million Yildiz Holding (Turkey) Godiva Chocolatier Weil, Gotshal and Manges, Kim Blanchard, Andrew Gaines Davis, Polk & Wardwell, Harry Ballan, Raymond Holst Acquisition $620 million Continental Energy Systems PNM Resources Cravath, Swaine & Moore, Michael Schler, Leonard Teti Troutman Sanders, Saba Ashraf Acquisition $525 million Avista Capital Partners Bristol-Myers Squibb Stikeman Elliott; Weil, Gotshal & Manges Cravath, Swaine & Moore Acquisition $450 million BAE Systems MTC Technologies Cravath, Swaine & Moore, Lauren Angelilli, Christopher Fargo Jones Day Acquisition e263 million ($387.6 million) Lion Capital AS Lathouwers SJ Berwin (UK), PricewaterhouseCoopers Acquisition £160 million ($313.4 million) Epicor Software NSB Retail Systems Travers Smith CMS Cameron McKenna Acquisition £144 million ($282 million) Cooper Controls MTL Instruments Group DLA Piper CMS Cameron McKenna Acquisition $265 million Ticketmaster TicketsNow O'Melveny and Myers, Brad Okun Perkins Coie, Bryan Smith, Lisa McGimpsey, Neal Hudders Acquisition $260 million NYSE Euronext Amex Wachtell, Lipton, Rosen & Katz, T Eiko Stange, Michael Sabbah Milbank, Tweed, Hadley & McCloy, Paul, Weiss, Rifkind, Wharton & Garrison Acquisition $250 million Citizen Watch Bulova Paul, Weiss, Rifkind, Wharton & Garrison, Jeff Samuels, Alyssa Wolpin, David Levine Acquisition e160 million ($232 million) The Carlyle Group & Mercapital Arsys Ernst & Young Lovells, Miguel Baz Acquisition $213.9 million Jinchuan Group Tyler Resources Davies, Ward, Phillips & Vineberg, Ian Crosbie & Duncan Osborne (Canada) Burnet, Duckworth & Palmer, David Ross Acquisition $163.6 million Hikma Pharmaceuticals Arab Pharmaceutical Manufacturing Company (APM) Ashurst Ernst & Young Acquisition e110 million ($162.1 million) Aberdeen Asset Management DEGI (real estate investment company of Dresdner Bank) Nörr Stiefenhofer Lutz, Georg Renner In-house counsel Acquisition $82 million Taiwan Semiconductor Manufacturing Atmel North Tyneside Simmons & Simmons, Nick Cronkshaw, Darren Oswick Herbert Smith, Howard Murray Acquisition $20 million Arasor International Novalux O'Melveny & Myers Acquisition £4.31 million ($8.47 million) London Town GRS Inns Mishcon de Reya, David Blumenthal Birketts Acquisition Undisclosed Nyesa Gestión Inbesòs Uría Menéndez, Cándido Paz-Ares, Guillermo San Pedro, Ana Pérez Escudero Icf Bufete Jurídico Fiscal Acquisition Undisclosed Baird Capital ESS Steel Eversheds, David Smith HLW, Andrew Hartley, Roger Dyson Acquisition Undisclosed Carillion Alfred McAlpine Slaughter and May, Steve Edge, Ruth Evans; Davis Polk & Wardwell CMS Cameron McKenna Acquisition Undisclosed The Royal Bank of Scotland and Bayerische Hypo- und Vereinsbank Allianz Freshfields Bruckhaus Deringer, Christian Sistermann Gleiss Lutz Type of Deal Value Issuer/borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) IPO $3 billion Eurasian Natural Resources Deutsche Bank Jones Day, Blaise Marin-Curtoud Cleary Gottlieb Steen & Hamilton, Richard Sultman, Russell Jones IPO $185 million NetSuite Credit Suisse Securities (US) Simpson Thacher & Bartlett, Benjamin Applestein IPO $170 million Mermaid Maritime BNP Paribas Capital & DBS Bank Baker & McKenzie Clifford Chance

Marco Da Re and Davide Bergami of Ernst & Young in Italy argue that Italy's independent line on permanent establishment could be a source of future problems for business