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Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M & A Undisclosed IBM, US Bowstreet, US Cravath, Swaine & Moore, Sharon Mendelson, Jeffrey Mande (US) Goodwin Proctor, US M & A $4.8 billion Lottomatica S p A GTECH Holdings Corporation Dewey Ballantine, Gordon Warnke and John Apadula (US) Cravath, Swaine & Moore, Michael Schler, Sean Thompson M & A €218 million ($267.7 million) Grosvenor Group 17% of Sonae Sierra, Portugal Slaughter and May, Graham Earles, Simon Letherman, KPMG (UK) In-house tax M & A Undisclosed Group AXA, France AXA Konzern AG (in connection with a voluntary public acquisition offer) Clifford Chance, Stefan Behrens, Germany M & A £37 million ($66 million) JS&P Holdings Towry Law from Henderson Group Slaughter and May, Paul Fahy (UK) Eversheds, Emma Channon (UK) M & A £143 million ($255 million) Unnamed Spanish investor Deka Immobilien's freehold interest in 100 Wood Street, London Clyde & Co PricewaterhouseCoopers M & A About €6.9 billion ($8.5 billion) Macquarie Infrastructure Group (MIG) and the Eiffage-Macquarie consortium Autoroutes Paris Rhin Rhône (APRR) Clifford Chance, Eric Davoudet, Anne de Dietrich (France) advised Macquarie Infrastructure Group (MIG) and the Eiffage/Macquarie consortium, Bredin Prat advised Eiffage and the Eiffage/Macquarie consortium Willkie Farr & Gallagher and Freshfields Bruckhaus Deringer (France) M & A Undisclosed Symantec Corporation (US) Imlogic (US) Fenwick & West, Ronald Schrotenboer and Adam Halpern In-house tax M & A $518 million Johnson & Johnson Animas Corporation Cravath, Swaine & Moore, William Brannan, Sharon Mendelson Pepper Hamilton Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Collateralized loan obligation (CLO) £5 billion ($8.9 billion) Barclays Bank Simmons & Simmons Clifford Chance (UK) Exchangeable bond Issue €572.8 million ($703.1 million) Parapública (Participações Públicas (SGPS)) Citigroup Global Markets and Caixa - Banco de Investimento Morais Leitão Uría Menéndez, Filipe Romão (Portugal) Initial public offering £150 million ($267.5 million) QinetiQ Group Credit Suisse, JPMorgan Cazenove and Merrill Lynch Herbert Smith Freshfields Bruckhaus Deringer, Jonathan Cooklin, Mark Boyle (UK), Claude Stansbury (US)

E-filing is the future of tax returns A large proportion of US companies have failed to prepare for the migration to e-filing, a new survey has revealed.

The American Jobs Creation Act of 2004 added section 7874 to the Internal Revenue Code to combat the perceived abuse of inversions of US corporations into foreign corporations. The statute is overly broad and, as a result, ordinary restructuring transactions involving affiliated corporations may generate significant adverse federal income tax consequences. The temporary regulation just issued fixes much of the overreach problem.

The UK government published draft legislation relating to real estate investment trusts (Reits) on December 14. It is anticipated that this regime will be available from January 1 2007. The basic idea is that the Reit will not be subject to UK tax on its property income and gains, but tax on such income and gains will be paid only by the investors in the Reit.

The codification of the economic substance doctrine in the US Senate's tax reconciliation legislation may have significant ramifications for bona fide business transactions that are far removed from the tax shelter transactions that are the intended target of the legislation, according to the American Bar Association's Section of Taxation.

Nearly 20 years after the US Congress enacted legislative changes to Internal Revenue Code section 863(d) and (e) in the Tax Reform Act of 1986, a new set of proposed regulations governing the characterization and source of income from space and ocean activities and international communications activities were released in autumn 2005. (Proposed Regulations sections 1.863-8(h) and 1.863-9(l).) These proposed rules replace a previous set issued in 2001.

Although a tax reform is expected in 2006, the Spanish government has recently announced a previous anti-avoidance reform that will affect various taxes. The text made public is a Bill that will probably go under extensive changes during its parliamentary proceedings, but its most significant proposals may be summarized as follows:

Jeffrey Levenstam has resigned as Cisco Systems' senior director of international tax and customs, to become a member of Ernst & Young's international tax services group in San Francisco. Lisa Peschcke-Koedt, has left Agilent Technologies, where she was vice-president for global tax at Agilent, to replace Levenstam at Cisco.

Robert Green has left the US Internal Revenue Service to become a member of Caplin & Drysdale's international tax practice in its Washington, DC office. As director, international at the IRS, he was responsible for the US' cross-border negotiations and controversies with its treaty partners and dealt with other issues such as cost sharing.

Richard Fletcher, a director of LECG, an economic advisory firm, has joined Baker & McKenzie in London as senior director - head of UK transfer pricing.