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Barbara Angus: room for a firm with people of our experience Two senior US government tax officials, Barbara Angus and Gregory Nickerson, have left public service to set up their own tax consultancy firm. Angus & Nickerson opened for business in Washington, DC on February 7 2005.

Marks & Spencer's former deputy head of tax, Philip Martin, explains the ramifications if the European Court of Justice sides with the retailer over group relief

The US President's Advisory Panel on Federal Tax Reform has its own website at www.taxreformpanel.gov.

A transaction in a supply chain in which missing trader fraud is discovered still qualifies as an economic activity for tax purposes, in the opinion of an advocate general of the European Court of Justice. The opinion came in three joined cases of traders, Optigen, Bond House Systems and Fulcrum Trading, against UK Customs & Excise (C-355/03, C-484/03 and C-354/03).

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:

Oman became one of the first countries in the Gulf region to benefit from a ruling from the Supreme Court on the scope of income liable to tax.

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%.

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

Gide Loyrette Nouel intends to develop a tax capability in all its offices after the appointment of Anthony Davis as a partner in London. Davis moves from the London office of Cadwalader, Wickersham & Taft, where he was also a partner. He is Gide's first tax partner in London.

Last Tuesday on February 22 2005 O2, a UK mobile phone operator, released new software that separates business and personal mobile calls, helping tax directors comply with value-added tax (VAT) requirements.