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The UK tax authorities published two consultation documents on June 20 looking for the views of taxpayers and practitioners on a system of advance rulings and clearances and a new approach to dealing with transfer pricing enquiries. The consultation period for both initiatives ends on September 13.

Vincci Lo tells Ralph Cunningham how rapidly developing tax systems and more intricate transactions ensure she is kept going to maintain efficient tax affairs for Lexmark in the Asia-Pacific region

John Rainsford, a senior VAT manager, at Smith & Williamson exposes the impact of Revenue delays on VAT registration

Ilya Rybalkin and Ivan Meleshenko, of Hogan & Hartson in Moscow, look at a change in the law

Ray Wiacek, head of the global tax practice at Jones Day, argues that new IRS FTC regulations are contrary to some fundamental principles of tax administration

Jane Kennedy, the new financial secretary to the Treasury, will have overall responsibility for the tax system in the government of Gordon Brown, the new British prime minister.

Viva Hammer International law firm Crowell & Moring has opened a tax consulting practice in New York. Viva Hammer joins as the first tax partner in the office.

Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition CS51.7 billion ($48.5 billion) Teachers' Private Capital et al BCE Goodmans (Carrie Smit, Miitch Sherman, Canada); Weil Gotshal & Manges Acquisition $10.3 billion Bain Capital; Carlyle; Clayton, Dubilier & Rice HD Supply Debevoise & Plimpton (David Schnabel, Rafael Kariyev, US) Wachtell Lipton Rosen & Katz (Debbie Paul,US) Merger $8.2 billion Silver Lake; TPG Avaya Ashurst (German, Italian, UK advice) Klaus Herkenroth, Nina Siewert, Nicole Benzler, Germany); Ropes & Gray (US advice) Weil Gotshal & Manges; Skadden, Arps, Slate, Meagher & Flom Acquisition €4.622 billion ($6.3 billion) Deutsche Sparkassen- und Giroverband Landesbank Berlin Holding Freshfields (Martin Schiessl, Germany) Merger about £3 billion ($6.03 billion) First Choice Holidays and TUI Tourism Ashurst [as adviser to Lazard, Deutsche Bank and Morgan Stanley] Demerger and public listing £2.6 billion ($5.2 billion) Mondi Group (demerged from Anglo-American) Allen & Overy [as adviser to lead sponsors UBS and Goldman Sachs] Acquisition $3.05 billion Saudi Telecom Company Maxis Communications (25%); NTS (51%) Freshfields Acquisition £1.44 billion ($2.9 billion) Cinven BUPA Hospitals Freshfields Slaughter and May (William Watson, Alisa Greda, Dominic Robertson, UK) Acquisition C$2.6 billion ($2.48 billion) Onex Healthcare Holdings Kodak's health group Goodmans (Yi-Wen Hsu, Canada); Kaye Scholer (US) Acquisition (50%) €1.3 billion ($1.8 billion) RREEF Infrastructure Tank & Rast Freshfields (Stephan Eilers, Germany) Acquisition $1.8 billion Rexam O-I Plastics Allen & Overy (Lydia Challen, Anita Anand, London) Acquisition €1.17 billion ($1.6 billion) Quinlan Private Jurys Inn Allen & Overy (Chris Harrison, London) Acquisition C$1.37 billion ($1.3 billion) New World Gaming Partners Gateway Casinos Income Fund Gowlings (for Macquarie) Goodmans [representing Clairvest, a shareholder in Gateway Casinos and Gateway Casinos Income Fund] (Mitch Sherman, Marisa Wyse, Canada); Borden Ladner Gervais Acquisition about €570 million ($776 million) Foncière des Régions GE Real Estate's stake in Technical De Pardieu Brocas Maffei (Emmanuel Chauve, Alexandre Blestel, France) Cleary Gottlieb Steen & Hamilton (Pascal Coudin, France) Acquisition HK$4.2 billion ($537 million) Smart Triumph Corporation China Oriental Group Slaughter and May [as adviser to Macquarie(Hong Kong), financial adviser to Smart Triumph Corporation] Reverse takeover £250 million ($503 million) Equator Exploration CAMAC Energy Holdings Slaughter and May Acquisition €249 million ($340 million) GMAC Insurance Provident Insurance Plc KPMG (Mike Bacon, Rob Lant, Gavin Little, UK) PricewaterhouseCoopers Acquisition £204.4 million ($279 million) Cerberus European Investments Torex Retail Ashurst (Tom Cartwright, London) Linklaters Acquisition (49%) €137 million ($187 million) Publicis Business Interactif Veil Jourde Gide Loyrette Nouel Acquisition about $183.5 million HIS Jane's Information Group Allen & Overy (Patrick Mears, Tessa Brentnall, London) Acquisition (30%) Undisclosed Palamon Capital Partners D&D Media Group

Boake Allen Ltd & Others v HMRC [2007] (NEC Semi-Conductors) Advance Corporation Tax (ACT) was payable on dividends in the UK between 1973 until it was abolished in April 1999. ACT was effectively a prepayment of mainstream corporation tax and could therefore be offset against a company's liability. Groups of UK companies could avoid the necessity to pay ACT on dividends paid between them by making a group income election under s247 ICTA 1988.

Roberto del Toro Francisco José Zamora Among the several anti-abuse provisions that were incorporated in the 2007 tax reform, new rules against the transferring of net operating losses (NOLs) were enacted, in specific when there is a change in the shareholders' control of an entity.