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The Canadian revenue authority has issued a taxpayer's charter. This suggests that taxpayers would have certain commitments from the taxman. Chris Sanger, head of tax policy at Ernst & Young in the UK, speculates on what might be in a new UK version

Rob Withecombe, head of tax at Grant Thornton UK, is sceptical about the outcome of an OECD project which will risk-assess tax advisers

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.

Bob van der Made On May 2007, the European Commission issued a communication on the progress made on the Common Consolidated Corporate Tax Base (CCCTB) which also includes an outline of the work still to be done. The European Commission remains committed to presenting a legislative proposal in 2008.

Stephen Nelson The PRC State Administration of Taxation issued a notice on April 4 2007 (Guoshui (2007) 403) interpreting the Hong Kong-China double tax arrangement (DTA) The notice is of relevance not just to Hong Kong tax residents, because it also is applicable to other tax treaties if the relevant issues are identical and no prior interpretation has been issued. There are many aspects in the notice that deserve attention but for the present discussion, we will focus on permanent establishment (PE).

Ricardo Zúñiga In concord with a trend of tax reform during the last months, the governments of the Central American countries have adopted or are discussing new legislation as part of an implementation programme provided for by the Free Trade Agreement between Dominican Republic, Central America and the United States of America (DR-CAFTA). New tax legislation is under discussion to comply with a preparatory schedule of regional reforms prior to engage in trade negotiations with the EU. This agreement with the EU would also include Dominican Republic and Panama as signatory countries. Other pieces of legislation would be issued with the purpose to facilitate compliance with domestic tax obligations and formal duties.

Bill Maclagan Kevin Zimka The Canadian government introduced its 2007 Budget on March 19 2007 (the budget), and dealt with a series of items in the international tax area, including matters relating to the Canada-United States Tax Convention (1980)(the Treaty). In the Budget the government announced that it was close to finalising a new protocol to the Treaty (Protocol).