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Until December 31 2004, Mexican tax law subjected Mexican taxpayers to immediate taxation on income generated indirectly in jurisdictions deemed to be tax havens. A list of countries deemed to be tax havens was included as an appendix to the law.

The second Budget of the Martin government, and the first of his minority government, was designed to appeal to voters with broad spending in numerous areas.

The introduction of the so-called notional interest deduction (as announced in the February edition) is on the right track. On March 4 2005, it was approved by the Belgian Council of Ministers and, as a result, the draft law is expected to be voted on in June 2005.

Issues concerning transfer-pricing methodology in the Japan-US Tax Treaty should have a significant effect on audits and the advance pricing agreement process, believes Kazuo Taguchi, of Baker & McKenzie

In 2004 the OECD released a study on transfer pricing issues arising from employee stock option plans. Gareth Green of Transfer Pricing Solutions, William Franklin of Pinsent Masons and Mike Heimert of Ceteris consider what can be learned from it

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $370 million Johnson & Johnson Closure Medical Cravath, Swaine & Moore, New York, William Brannan, Sharon Mendelson, Jeffrey Mandel, Young Park Morgan Lewis, Philadelphia, Jeffrey Korenblatt M&A $2.2 billion Medco Health Solutions Accredo Health Sullivan & Cromwell, New York, William Indoe, David Passey, Martin Hamilton Alston & Bird M&A $385 million Kelso & Company Insurance Auto Auctions Skadden, Arps, Slate, Meagher & Flom, New York, David Rievman, Pamela Lawrence Endreny KMZ Rosenman, Chicago, Saul Rudo M&A $1.47 billion Yellow Roadway Corporation USF Corporation Fulbright & Jaworski, Houston, John Allender Sullivan & Cromwell, New York, Ronald Creamer M&A $17 billion Federated Department Stores The May Department Stores Company Jones Day, Cleveland, Daniel Hagen Skadden, Arps, Slate, Meagher & Flom, New York, Sally Thurston M&A £1.06 billion ($2.03 billion) Apax Partners Worldwide 3i Group agreed to sell Travelex Freshfields Bruckhaus Deringer, London, Jonathan Cooklin Dechert, London, David Gubbay; New York, Michael Hirschfeld M&A £1 billion ($1.93 billion) Marriott hotels Whitbread agreed to sell its Marriott hotels business. The company will form a 50/50 joint venture with Marriott to hold the hotel properties until they are sold. Macfarlanes, London, Ashley Greenbank Slaughter and May, London, Gillian Wheeler M&A $4.2 billion BAE Systems United Defense Industries Cravath, Swaine & Moore, New York, Michael Schler, David Ware, Grace Lee Gibson, Dunn & Crutcher, Washington, DC, Art Pasternak M&A A$9.2 billion ($7.3 billion) BHP Billiton WMC Resources Blake Dawson Waldron Allens Arthur Robinson M&A £1.1 billion ($2.1 billion) Aviva RAC Slaughter and May, London, Steve Edge, James Quinn, Martin Walker Herbert Smith, London, Bradley Phillips, David Jacob M&A $1.1 billion IBM Ascential Software Corporation Cravath, Swaine & Moore, New York, Patricia Geoghegan, Stephen Gordon, Jennifer Conway, David Dubner Skadden, Arps, Slate, Meagher & Flom M&A €5.5 billion ($7.32 billion) Metrovacesa Gecina Linklaters, Paris, Philippe Derouin Rambaud Martel, Paris, Roland Poirier M&A $3.5 billion Vodafone Telesystem International Wireless Linklaters, London, Andrew Beverley, Sabina Margulies; Prague, Ton Kemp, Dita Sulcova, Paula Hyblova; New York, Stephen Land Fasken Martineau DuMoulin, Montréal, Alain Ranger Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Fund issue £66 million ($127 million) Absolute Return Trust Cazenove & Co Herbert Smith In-house Securitization £2.1 billion ($4.05 billion) British Land Company and the Broadgate companies conducted a refinancing of the Broadgate Estate Morgan Stanley, The Royal Bank of Scotland and UBS Investment Bank Simmons & Simmons Allen & Overy, London, Mark Brailsford, Gareth Banfield Refinancing €515 million ($688 million) Saft Mizuho Ashurst Clifford Chance

Important differences in the tax treatment of equity and debt show that the new Mexican thin-capitalization rules are incomplete, argue Roberto Del Toro, John Salerno and Lisette Tautfest of PricewaterhouseCoopers

Anti-avoidance and Europe dominated the discussion of international tax matters after the UK Budget. Tax advisers explain to Ralph Cunningham what the government's plans mean for their clients