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The US Treasury and the Internal Revenue Service has issued guidance that designates "sale-in/lease-out" or "SILO" arrangements as abusive tax avoidance transactions.

Nick Gangemi, a former tax partner at Baker & McKenzie, has joined BDO in Australia as national tax technical director. BDO, the international tax and accountancy firm, announced that they had filled the newly-created position in their Sydney office.

Transfers of shares of companies resident in Spain are generally exempt from indirect taxes. In this sense, certain schemes have been tailored in order to avoid Spanish indirect taxes on transfers of real estate properties by transferring shares in companies whose main assets are real estate instead of the real estate itself. In order to block these schemes an anti-abuse provision was introduced in the Spanish transfer tax regulations in 1991, establishing that share transfers could trigger transfer tax at a 6% or 7% rate (depending on the Autonomous Community) provided that:

Among most recent decisions of the Supreme Administrative Court (SAC) in Poland, which is the highest tax court in Poland, one of them has a particular significance.

The avoidance "technique" relying on non-discrimination clauses in double tax agreements has been adopted in South Africa and was the subject of a mild furore recently, culminating in some amending legislation passed by parliament last year.

Mexican entities may now consolidate up to 100% of the taxable income or loss of group members, based on the top Mexican holding company's shareholdings in its Mexican subsidiaries. The increase in the proportion for calculating the participation will have no retroactive effects in connection with the years 1999 to 2004, in which the consolidation was based on the proportion of 60%.

In order to maintain its position as the place of choice for international transactions, Luxembourg has developed an extensive network of double tax treaties. At present 45 treaties have already been signed and a further 11 treaties are under negotiation. In this context, Luxembourg has just signed a treaty with Israel on December 14 2004. Once the said treaty has been ratified by both countries, its provisions should come into force as from January 1 2004.

The tax reform plan for 2005 includes a tax increase for partners of a partnership, as follows.

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $182 million IBM Corio Cravath, Swine & Moore, New York, Stephen Gordon Wilson Sonsini Goodrich & Rosati, San Francisco, David Gerson, Lia Alioto M&A C$3 billion ($2.4 billion) KKR Masonite Deloitte KPMG, Ontario, David Regan M&A Undisclosed Sigma-Aldrich Corporation Degussa agreed to sell the Proglio Group Bryan Cave, St. Louis, Dana Lasley, Philip Wright Freshfields Bruckhaus Deringer, Washington, Claude Stansbury M&A $6.7 billion Verizon Communications MCI Debevoise & Plimpton, New York, Lawrence Cagney, Gary Friedman, Peter Furci, Davis Polk & Wardwell, New York, Michael Mollerus, Nora Muller M&A C$270m ($219 million) Fort Chicago Energy Partners Alberta Ethane Gathering Systems KPMG, Calgary, Wayne Chodzicki, Shane Richardson McCarthy Tétrault, Calgary, Ian Bock; Toronto, James Warnock M&A C$1.8bn Rogers Communications acquired 34% of Rogers Wireless from AT&T Wireless Services 34% of Rogers Wireless KPMG, Ontario, Chris Sexton Fasken Martineau DuMoulin, Toronto, Alan Schwartz, William Bies M&A Undisclosed Firmenich International Noville Cravath, Swaine & Moore, New York, Stephen Gordon, David Ware Norris McLaughlin & Marcus, New York, Robert Marcus, John Eagan M&A $980 million Eastman Kodak Company Creo Stikeman Elliot, Toronto, Dean Allen Kraus Cravath, Swaine & Moore, New York, Michael Schler, Megan Healey M&A £131 million ($248 million) Close Brothers Singer & Friedlander Finance Ashurst, London, Alex Cox Field Fisher Waterhouse, London, Nick Beecham M&A $57 billion Fortress and Cerberus Consortium Boxclever Weil, Gotshal & Manges, London, John Baldry Richards Butler M&A $1.8 billion Procter & Gamble Gillette Cadwalader Wickersham & Taft, New York, Linda Swartz, Alexander Anderson, Yossi Cohen, Russell Nance Davis Polk & Wardwell, New York, Michael Mollerus, Melissa Loewenstern M&A £280 million ($530 million) Holcim Aggregate Industries Slaughter and May Freshfields Bruckhaus Deringer, London, Robert Kent M&A $182 million HBOS Electra Partners agreed to sell Ashbourne Allen & Overy, London, Vicky Stone Simmons & Simmons, London, Nick Cronkshaw, Clare Shah Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Mortgage-backed note programme £20 billion ($37.6 billion) Northern Rock Barclays Capital, Citigroup and Merrill Lynch Sidley Austin Brown & Wood Allen & Overy Loan facility £141 million ($267 million) CommerzLeasing and Immobilien Group (borrowers) Hypo Real Estate Bank NA Herbert Smith

Hans Eichel, Germany's finance minister, has announced that the government wants reforms of the corporate tax system to be in place by 2007.