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Taxpayers should be aware that time may still be on their side if they wish to make similar claims to Marks & Spencer. An analysis of other tax cases from the UK courts shows what is possible, explains Simon Whitehead of Dorsey & Whitney

The technical corrections legislation passed at the end of 2005 in the US will have an impact on international tax. Marjorie Rollinson and Michael Mundaca of Ernst & Young explain how this and budget reconciliation, yet to be agreed, will affect taxpayers in 2006

The Mexican Congress passed thin-capitalization rules in 2005 to stop taxpayers using excessive debt to avoid tax. Roberto del Toro, David Cuellar and Francisco José Zamora of PricewaterhouseCoopers explain how the rules were relaxed in 2006

The use of allowable losses and disclosure, but little on tax reform, featured in the UK government's pre-Budget statement. Gary Richards of Berwin Leighton Paisner warns that the system's complexity might mean that taxpayers will choose to leave the country

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.