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Risk is something that goes hand in hand with the oil and gas industry. Militants' guns in Nigeria, political tensions surrounding reserves in Russia and Venezuela and production uncertainty that paticipants must accept: the market faces it all. There is another challenger - the tax authorities. And as Catherine Snowdon finds out, they are raising the stakes

Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $38.1 billion Rio Tinto Alcan Goodmans (Yi Wen Hsu) Merger Transocean ($31.7 billion) GlobalSantaFe ($17 billion) Transocean GlobalSantaFe Baker Botts Skadden, Arps, Slate, Meagher & Flom Acquisition $16.8 billion Danone Royal Numico De Brauw Blackstone Westbroek Allen & Overy Acquisition $16.3 billion Akzo Nobel ICI Slaughter and May (Jeanette Zaman, Tim Woodthorpe) Freshfields (Robert Kent, Arun Birla) Acquisition $16.2 billion Imperial Tobacco Altadis Urìa Menéndez (Rafael García Llaneza) Garrigues Acquisition $15.6 billion Continental Siemens VDO Automotive Freshfields Bruckhaus Deringer (Ulrich Blaas) Hengeler Mueller (Martin Klein) Acquisition $7.9 billion Hypo Real Estate Depfa Freshfield Bruckhaus Deringer

Sue Bonney KPMG has announced that the head of its UK tax practice, Sue Bonney, will be in charge of tax for its European firm. KPMG is in the process of merging its British, German and Swiss operations. The Dutch firm is shortly to vote on its inclusion.

Jack Cummings Edward Tanenbaum IRS Notice 2007-57 adds a new category of listed transaction that involves loss importation. The technique involves the most elementary of planning techniques: the domestic taxpayer arranges to reflect on its US income tax return the loss leg of a hedge entered into by a foreign entity. In order to avoid also reporting on its US return the gain leg of the hedge, the taxpayer insures that the foreign entity is a corporation for US tax purposes when it recognises the gain. Finally, to close the loop, it is necessary for the US taxpayer not to own the foreign entity long enough as a corporation to have to report its income under subpart F.

There has been a long-running dispute on the dedutibility of hedging cost against premium derived from warrant issuances for Taiwan tax purposes. Previously, 25% income tax was levied on the warrant premium after accounting for origination costs rather than on the gains from the issuance of warrants. The rationale behind the foregoing tax treatment was based on the concept that capital gains from the trading of securities are tax-exempt whereas capital losses may not be tax-deductible.

Christoph Schärer, in Zurich, and Harvey Mayne, in Frankfurt, from PricewaterhouseCoopers explains why VAT risk is a major threat to businesses in the EU

US treasury department The US tax authorities have released the list of issues they hope to produce guidance on by June 2008. The priority guidance plan released by the IRS and the Treasury department's office of tax policy on August 14 contains 303 projects.

Eli Weiss, an attorney in the New York tax department of Frank Fried, has been elevated to the partnership. His practice focuses primarily on the representation of domestic and international clients in numerous transactions. He joined the firm in 1999.

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