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Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $12.8 billion CEMEX (Mexico) Rinker Group (Australia) Cravath, Swaine & Moore Stephen Gordon, Christian Brause Acquisition undisclosed Providence Equity Partners (US) Idea Cellular (India) Debevoise & Plimpton Peter Schuur, Mai Nguyen Acquisition $700 million Saudi Basic Industries Corporation (Saudi Arabia) Huntsman Corporation (European base chemicals and polymers business) Slaughter and May William Watson, Lee Khvat Acquisition undisclosed Morgan Stanley (US) FrontPoint Partners (US) Cravath, Swaine & Moore Michael Schler, Ellen Kandel-Burg Davis Polk & Wardwell Sam Dimon, Mary Conway, Seth Poloner, Lisa Mahle Acquisition $3.7 billion Kos Pharmaceuticals (US) Abbott Laboratories (US) Cravath, Swaine & Moore Michael Schler, Vinay Shandal Holland & Knight Steven Sonberg Acquisition £1.6 billion ($3.15 billion) Blackstone (US), PAI Partners (France) United Biscuits Herbert Smith, Simpson Thacher Bartlett Allen & Overy, Feeshfields Bruckhaus Deringer Acquisition €4 billion ($5.32 billion) KKR (US), Goldman Sachs Capital Partners (US) Kion (Germany) Freshfields Bruckhaus Deringer Cyril Valentin, Claude Stansbury, Norbert Schneider Acquisition undisclosed Morgan Stanley Investment Management (US) Lansdowne Partners (UK) Slaughter and May Tony Beare, Dominic Robertson, Davis Polk & Wardwell Acquisition attempt $3.7 billion Isadore Sharp (Canada), Triples Holdings, Kingdom Hotels (Dubai), Cascade Investment (US) Four Seasons (Canada) Ogilvy Renault, Hogan & Hartson, Stikeman Elliott, Cleary Gottlieb Steen & Hamilton, McCarthy Tetrault Goodmans, Wachtell, Lipton, Rosen & Katz, Osler Hoskin & Harcourt Acquisition $25.9 billion Freeport-McMoran Copper (US) Phelps Dodge (US) Debevoise & Plimpton Peter Furci, Hugh Rowland Jr, Gabriela Palmieri Acquisition €865 million ($1.15 billion) Lagardère (France) Sportfive (Germany) Clifford Chance Eric Zeller, Etienne Genot Ashurst Klaus Herkenroth, Nina Siewert Acquisition $8 billion CSN (US) Corus Group (UK/Netherlands) Cravath Swaine & Moore Shearman & Sterling Acquisition $1.4 billion Johnson & Johnson (US) Conor Medsystems (US) Cravath Swaine & Moore William Brannan, Anne Kim Cooley Godward Kronish Merger $2.4 billion Ripplewood Holdings (US) Reader's Digest Association (US) Cravath Swaine & Moore William Brannan, Anne Kim Jones Day Acquisition HK$5.2 billlion ($668 million) GOME Electrical Appliances (Hong Kong) China Paradise Electronics Retail (China) Freshfields Bruckhaus Deringer Herbert Smith Acquisition €670 million ($890 million) Eurazeo/Europcar Groupe (France) National and Alamo Rent a Car (US) Bredin Prat Sebastien de Monès, Pierre-Henri Durand, Slaughter and May Richard Carson, Hengeler Muller Hermann-Josef, Tries Lars Kloster Acquisition £1.2 billion ($2.4 billion) Givaudan (France) Quest International (UK) Herbert Smith Derek Hill, Perminder Gainda Freshfields Bruckhaus Deringer Merger n/a Derwent Valley Holdings (UK) London Merchant Securities (UK) Slaughter and May William Watson, Gareth Miles Acquisition undisclosed IBM (US) Vallent (US) Cravath Swaine & Moore Andrew Needham, Rebecca Kysar Wilson Sonsini Merger €2.5 billion ($3.32 billion) Autostrade (Italy) Abertis (Spain) Uría Menéndez Rafael Fuster Acquisition €153 million ($203 million) TA Associates (US) eDreams (Spain) Ashurst Richard Palmer, Ceri Stoner, Stefano Serbini Freshfields Bruckhaus Deringer, Garrigues Acquisition £1.27 billion ($2.5 billion) Premier Foods (UK) RHM (UK) Weil Gotshal & Manges Doug Nave, Jane Scobie Ashurst UK Type of deal Value Issuer/Borrower Lead managers/ lenders Adviser to issuer/borrower (tax) Adviser to lead managers (tax) IPO $19.1 billion Industrial & Commercial Bank of China (China) China International Capital (China), Credit Suisse (Switzerland), Deutsche Bank (Germany), ICEA Holdings, Merrill Lynch (US) Herbert Smith, King & Wood, Davis Polk & Wardwell Shearman & Sterling, Freshfields Bruckhaus Deringer, Haiwen & Partners Bond financing $925 million Blue City Project (Oman) Bear Stearns (US) Cifford Chance Shearman & Sterling Securitisation refinancing £650 million ($1.28 billion) Telereal (UK) Freshfields Bruckhaus Deringer Sue Porter, Peter Cosmetatos Bond offering $2.25 billion Xstrata (Switzerland) Barclays Capital, JP Morgan (US), RBS Greenwich Capital (UK) Clifford Chance Helen Smyth, John Gower, Avrohom Gelber

Sean Foley The Treasury Department and IRS have released new proposed regulations regarding the determination of the income and currency gain or loss of a section 987 qualified business unit (QBU). The intention is to prevent taxpayers from recognizing what are considered to be non-economic foreign exchange losses. The proposed regulations withdraw the existing proposed rules, which were issued on September 25 1991.

Edward Tanenbaum Kevin Rowe Under the mutual agreement provision of the United States-United Kingdom Income Tax Treaty, (the Treaty,) the US and the UK competent authorities have agreed to alleviate potential double taxation under the dual consolidated loss (DCL) regimes of both countries. This is the first bilateral agreement under section 1.1503-2(g)(1) of the regulations.

The UK tax authorities Her Majesty's Revenue & Customs (HMRC) have published draft guidance on the effect of the Indofood decision (Indofood International Finance Limited v JP Morgan Chase Bank NA, London Branch). This may have implications for cross-border financing structures, particularly on-lending structures, which rely on a double taxation convention (DTC) to eliminate UK withholding tax on interest. The draft guidance focuses on the interpretation of beneficial ownership in the context of such DTCs. To benefit from the terms of such a DTC, it is usually a requirement that the recipient of the income in question is the beneficial owner of it. The guidance indicates that HMRC will be adopting a narrower interpretation of beneficial ownership (which HMRC refer to as the international fiscal meaning) in the context of DTCs than its general meaning in UK tax law. HMRC indicate that in order to be the beneficial owner under the "international fiscal meaning" it is necessary that the recipient "enjoys the full privilege to directly benefit from the income". Employing this definition may prejudice the availability of treaty relief.

Maire Walsh Residents of Zug, a Swiss canton, voted in favour of a revision of the Cantonal Tax Law. The following changes represent the most relevant of the revisions and will come into effect on January 1 2007.

Carl Pihlgren Dunja Brodic The National Board on Advance Rulings recently rendered a decision regarding the Swedish rules on exit taxation and the reversal of tax allocation reserves when a company ceases to be a tax resident in Sweden due to tax treaty provisions. In summary, the Board ruled that the Swedish rules pursue an objective in the public interest, but are nevertheless contrary to the freedom of establishment as they go beyond what is necessary to obtain the objective they pursue.

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FASB has tried hard to address the question of uncertain tax positions. But its new standard fails to deal with all the issues, believe Hira Sharma of Chiltern, and Jim Eberle of Alvarez & Marsal

Bob van der Made On December 12 2006, the European Commission will hold its second joint consultation meeting on the CCCTB with business and academics in Brussels. This meeting will be followed by a meeting the next day between the Commission and EU member state experts in the Common Consolidated Corporate Tax Base (CCCTB) Working Group. The aim of these meetings will be to take stock of progress in 2006 and discuss how to further build the CCCTB. The working assumption of the Commission is still that a legislative proposal for a CCCTB can be presented to Council and Parliament by the end of 2008.

Roberto del Toro The Maquiladora programmes were established to promote labor in Mexico, by providing certain customs and tax benefits.