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  • The input of senior officials from the US, UK and German governments, the European Commission and a former US assistant secretary for tax policy ensured that the government panel at the annual ABA/IBA tax planning strategies meeting in Frankfurt on April 19 and 20 would be a lively one.
  • Tax is intimately wrapped up in the discussions about to help the environment. Policy makers have identified charging businesses and individuals more when they contribute to climate change as one method. Another is emissions trading systems, where businesses can buy and sell allowances according to how much greenhouse gases they emit.
  • Edward Tanenbaum The Advice Memorandum 2007-006 is generic legal advice from chief counsel to the IRS field, assuring the field that a domestic corporate purchaser of a foreign target eligible entity (treated as a default corporation) can make a section 338(g) election and step up the basis of the target's assets, despite the fact that no US tax will be paid, and whether or not the election is extended to a US subsidiary of the target. The target was irrelevant for US tax purposes prior to the purchase, meaning generally that it had no US owners or business.
  • Oleh Marchenko Although the political situation may slow down the process, the Ukraine's State Tax Administration and government are actively pushing through enactment of a tax code. The tax code is expected to be largely a compilation of the existing tax law. However, some tax policy changes are also considered.
  • Matthew Desborough-Hurst The Chancellor, Gordon Brown, gave his annual Budget on March 21 2007.
  • Carl Philgren Earlier this year the National Board on Advance Rulings as a consequence of the Marks & Spencer case (C- 446/03) made several decisions regarding the Swedish group contribution system. In somes cases the rulings have been appealed by the Swedish tax authority.
  • Jim Flaherty, Canadian Finance Minister: adamant the deduction will be removed Taxpayers in Canada are furious with the government over a plan announced in the budget in March to remove a provision that allowed interest expense deductions from investments abroad.
  • In March, leaders from the EU's 27 member states pledged to cut carbon emissions by 20% of their 1990 level by 2020. Many believe that such an ambitious target is unlikely to be reached without an EU-wide carbon tax. But Claire Jones finds out rules on taxation and political opposition present difficulties
  • Increasing the tax burden is not the only way to help the planet, believes Chris Wales
  • Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition attempt €35 billion ($47.8 billlion) Porsche (Germany) Volkswagen (Germany) Freshfields Bruckhaus Deringer (Wilfried Schaefer, Germany) Acquisition €2.4 billion ($3.3 billion) Charterhouse Capital Partners (UK) ista International (Germany) KPMG (Anneli Collins, UK; Christian Jänisch, Lars Behrendt, Germany) Freshfields Bruckhause Deringer (Stephan Eilers, Germany) Ernst & Young (Klaus Krämer-Erkrath, Michael Vogel, Germany) Acquisition £242.5 million ($486 million) Lupus Capital (UK) The Laird Group (Security Systems division) (UK) Slaughter and May (William Watson, Paul Fahy, UK) Ashurst (John Watson, Nicholas Gardner, Fellicity Alcindor, UK) Acquisition €11 billion ($14.5 billion) Schering Plough (US) Akzo Nobel (Organon BioSciences division)(The Netherlands) Allen & Overy (Olaf van der Donk, the Netherlands) De Brauw Blackstone Westbroek (Michiel Sundeman, the Netherlands) Acquisition €1.3 billion ($1.8 billion) Cinven (UK) Phadia Holding (France) KPMG (Mathew Macauley, Gill Slater, Arnout Haeser, Neil O'Brien, Ed Murphy, UK; Per Snellman, Carina Terinus, Sweden; Birgit Hoefer, Claudia Belser, PricewaterhouseCoopers (Melanie Malsbury, UK) Acquisition £950 million ($1.9 billion) Cinven (UK) Gondola Holdings (UK) Mathew Macauley, Arnout Haeser, Neil O'Brien, Ed Murphy, Jo Quelch, Amanda Allan, UK; Birgit Hoefer, Claudia Belser, Luxembourg) PricewaterhouseCoopers Acquisition £615 million ($1.2 billion) EQT (Sweden) Scandic (Sweden) KPMG (Jan Kallqvist, Carina Terenius, Jonas Henriksson, Per Degerman, Bjorn Johansson, Maria Nielsen, Sweden) Acquisition C$804 million ($1.6 billion) Caxton-Iseman Capital (UK) KCP (Canada) Paul Weiss Rifkind Wharton & Garrison (US), Blake Cassels & Graydon (Canada) Goodmans (Carrie Smit, Stacey Long, Canada) Acquisition £96 million ($192 million) Tragus Group (UK) La Tasca (UK) Ashurst (Patricia Allen, UK) Dickson Minto (UK) Acquisition €180 million ($2464 million) Private Equity Partners (Italy), Mid Equity Partners Ferdinando Giordano (Italy) Ashurst (Paola Flora, Italy) Studio Tosettto, Weigmann e Associati (Andrea Bernardini, Federico Restano, Italy) Acquisition undisclosed JS&P Towry Law (UK) Baker Tilly Financial Services (International) Slaughter and May (Graham Iversen, Timothy Woodthorpe, UK) Acquisition $315 million Global Aero Logistics (UK) World Air Holdings (US) Cravath, Swaine & Moore (Michael Schler, Leonard Teti, US) Powell Goldstein (US) Acquisition £740 million ($1. 5 billion) Management buy-out Jupiter (UK) Norton Rose (UK) Clifford Chance (David Harkness, Helen Corner, UK) Acquisition £588m ($1.2 billion) Consortium led by ABN Amro (the Netherlands) Corey Environmental (UK) PricewaterhouseCoopers KPMG (Iain Clarke, David Kilshaw, Jo Quelch, UK)Acquisition €2 billion ($2.73 billion) Bayerische Hypo- und Vereinsbank (Germany) UniCredit Banca Mobiliare (Italy) Norton Rose (Antonello Lupo, Fabio Chiarenza, Francesco Nardacchione, UK) In-house counsel Type of deal Value Issuer/Borrower Lead managers/ lenders Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Securitisation financing $182.5 million Puma Capital (Germany) Dresdner Kleinwort (Germany) Maples and Calder (Cayman Islands) Norton Rose (Matt Hodkin, UK), Lovells IPO £700 million ($1.4 billion) 3i Infrastructure (UK) Citigroup Global Capital Markets (US) Slaughter and May (Steve Edge, Abigail McGregor) Freshfields Bruckhaus Deringer Formation of investment fund €2.25 billion (S3.1 billion) n/a Intermediate Capital Group n/a Ashurst (Ian Johnson, Alastair Ladkin, UK)