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  • Belgium is already known as an attractive region for estate planning but new rules make it even more attractive. Movable property given "from hand to hand" was already exempted from gift tax. However, if the donor dies within three years from the date of such gift, the gift is deemed to be a legacy and will be subject to inheritance tax (at the progressive rates).
  • The taxation of Austrian and foreign investment funds is now more similar due to a decision of the Austrian Constitutional Court and the Tax Amendment Act 2004 (Abgabenänderungsgesetz 2004).
  • It is now a lot more difficult for foreign offshore companies that want to open an Argentine branch or buy shares in the country. Through Resolution 2/2005, the Argentine corporate regulatory authority (Inspección General de Justicia or IGJ) has toughened their position against foreign offshore companies planning to register an Argentine branch or become a shareholder in local companies.
  • A favourable tax regime exists now for international investors in Spanish finance companies. For example, no withholding tax applies on the yields derived from the investment, explain José Ignacio Jiménez-Blanco and José Ma Cusí of Clifford Chance
  • The UK-Reit discussion is firmly back on the government's agenda. Cathryn Vanderspar of Berwin Leighton Paisner examines where the UK is in the process, the main tax hurdles still to be surmounted and some of the opportunities that may arise
  • Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A (Leveraged buyout) $11.3 billion A consortium organized by Silver Lake Partners that includes Texas Pacific Group, Bain Capital, Blackstone Group, Kohlberg Kravis Roberts & Co, Goldman Sachs Capital Partners and Providence Equity Partners SunGard Ashurst, London, Richard Palmer; Ropes & Gray, Boston, Chris Leich, Amanda Holt Shearman & Sterling, New York, Laurence Bambino, Don Lonczak M&A Undisclosed Highland Capital Management ING Bank agreed to dispose of ING Capital Management Skadden, Arps, Slate, Meagher & Flom, London, Tim Sanders Ashurst, London, Ian Johnson, Alexander Cox, Robert O'Hare M&A £100 million ($188 million) CKX Simon Fuller and Ingenious Ventures agreed to sell 19 Entertainment Baker & McKenzie, London, James macLachlan, James Smith Harbottle & Lewis, London, Glen Atchison, Louise Gordon M&A $1.85 billion IAC/Interactivecorp Ask Jeeves Wachtell, Lipton, Rosen & Katz, New York, Jared Rusman Gibson Dunn & Crutcher M&A $1 billion Goldner Hawn Johnson & Morrison ShopKo Stores Skadden, Arps, Slate, Meagher & Flom, New York, Stuart Finkelstein Sidley Austin Brown & Wood, Chicago, Mary Niehaus M&A $18 billion ChevronTexaco Corporation Unocal Corporation Pillsbury Winthrop, New York, Susan Serota Wachtell, Lipton, Rosen & Katz, New York, Deborah Paul M&A (joint venture) £366 million ($702 million) Joint venture between Consensus Business Group and Tesco Tesco will contribute 12 of its stores and two distribution centres to a Jersey limited partnership owned 50% by Tesco and 50% by Consensus. The stores and centres are let to Tesco on 27-year leases, with Tesco retaining the option to buy them back Consensus was advised by Herbert Smith, London, Neil Warriner Tesco was advised by Berwin Leighton Paisner, London, Charles Goddard, Gary Richards M&A (joint venture) €100 million ($131 million) Terranova Energy Corporation shareholders Ceatesalas, SL, Corporación Eólica CESA, SA and Ceolica USA Corporation Uría & Menéndez, Barcelona, Luis Viñuales Cuatrecasas M&A Undisclosed Albemarle Corporation Akzo Nobel agreed to sell its Spanish catalysts business unit Hunton & Williams Uría & Menéndez, Barcelona, Marc Ciutat M&A £2.8 billion ($5.36 billion) Fortune Brands Pernod Ricard agreed to sell spirits brands including Sauza, Maker's Mark, Courvoisier, Canadian Club, Laphroaig and Teachers Herbert Smith, London, Bradley Phillips, Derek Hill, David Mogford Macfarlanes, London, Ashley Greenbank, Elizabeth Sherwood M&A £7.4 billion ($14.1 billion) Pernod Ricard Allied Domecq Macfarlanes, London, Ashley Greenbank, Elizabeth Sherwood Linklaters, London, Guy Brannan, Lynne Walkington M&A $1.6 billion Shire Pharmaceuticals Group Transkaryotic Therapies Davis Polk & Wardwell, New York, Avishai Shachar, Neil Barr Cravath, Swaine & Moore, New York, Andrew Needham M&A $990 million RR Donnelley & Sons Company The Astron Group Ashurst, London, Ian Johnson, Tom Cartwright Eversheds, London, Bo Kehinde M&A Undisclosed IBM Healthlink Incorporated Cravath, Swaine & Moore, New York, Alyssa Wolpin, Megan Healey Dorsey & Whitney M&A $3.4 billion Adobe Systems Macromedia Cooley Godward, Palo Alto, Robert Miller Fenwick & West, Mountain View, California, Ronald Schrotenboer Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Financing £152.5 million ($286 million) Insight Foundation Property Trust NM Rothschild and Merrill Lynch Herbert Smith Clifford Chance Securitization £1.06 billion ($2.03 billion) The Mall Fund CSFB and RBS PricewaterhouseCoopers Freshfields Bruckhaus Deringer, London, Sue Porter, Peter Cosmetatos Securities issue £350 million ($657 million) Old Mutual UBS Investment Bank and Barclays Capital Slaughter and May Linklaters
  • The 2005 South African Budget was not as dramatic in tax terms as some recent ones. However. it still contained a number of significant company tax proposals, explains Anne Bennett of Deloitte
  • In an interview with Sed Crest in Washington, DC, Senator Connie Mack, chairman of the President's Advisory Panel on Federal Tax Reform, revealed his thoughts on how to reform the US tax system
  • The introduction of a notional interest deduction and 0% capital duty into Belgian tax law will boost the appeal of the country for international taxpayers, argue Kurt De Haen and Koen Cooreman of PricewaterhouseCoopers
  • Larry Sussman: Multinationals are relocating to export processing zones to avoid VAT China's State Administration of Taxation has released a number of notices bringing together the tax rebate (exemption) rules.