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The US Treasury and the Internal Revenue Service (IRS) have released clarification on the one-time tax break on profit repatriation and the manufacturing deduction in the American Jobs Creation Act (AJCA).

A tax partner has left Gleiss Lutz, a German law firm, to set up independently. Wolfgang Blumers took two tax associates, Diethard Goerg and Ulrich-Peter Kinzl, with him to set up the Stuttgart-based boutique Blumers & Partner.

The decision of one of Singapore's leading tax litigators to close his own firm and move to one of the city-state's biggest corporate and financial law firms, is down to the desire of international companies for corporate firms to handle their tax affairs.

A process involving financial ratios can evaluate, on a regional basis, the existence of task risk and opportunities for tax process improvements, explains Franco Antognini of Ernst & Young

At the end of 2004, the House of Lords gave their verdict in two important tax avoidance cases. Barclays Mercantile and Scottish Provident provided mixed results for taxpayers, reveals David Taylor of Freshfields Bruckhaus Deringer

Although value-added tax is usually relevant to outsourcing, there are plenty of other tax issues to consider, explain Iain Scoon and Stephen Pevsner of Shearman & Sterling

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $1.7 billion Lenovo Group IBM Corporation agreed to sell its personal computers business Clifford Chance Cravath, Swaine & Moore, New York, Lewis Steinberg M&A £93 million to £120 million ($176 million to $227 million) Britannic Assurance Allianz Cornhill agreed to sell its life insurance business Herbert Smith, London, Howard Murray Slaughter & May M&A $1.1 billion Carl Zeiss AG and EQT III fund Sola International Davis Polk & Wardwell Cahill Gordon & Reindel M&A £1.27 billion ($2.38 billion) Macquarie Communications Infrastructure Group NTL agreed to sell its antenna towers business Travers Smith Allen & Overy, London, Patrick Mears M&A $1.1 billion General Electric Company Ionics Weil Testa, Hurwitz & Thibeault, Boston, William Corcoran, Kimberly Collins, Warren Goodworth M&A Undisclosed Randall & Quilter ACE agreed to sell three companies forming part of ACE's Brandywine run-off division Lovells Debevoise & Plimpton, New York, Seth Rosen, Matthew O'Halloran M&A €300 million ($398 million) Deutsche Bank agreed to sell a portfolio of 109 properties in Germany Eurocastle Investment, an investment company managed by Fortress Investment Group Freshfields Bruckhaus Deringer Linklaters Oppenhoff & Rädler, Frankfurt, Jens Blumenberg M&A $25 billion Johnson & Johnson Guidant Corporation Cravath Skadden, Arps, Slate, Meagher & Flom, Chicago, Louis Freeman, David Weil M&A £700 million ($1.3 billion) Cendant Corporation Gullivers Travel Associates and Octopus Travel Group Skadden Slaughter and May, London, Graham Airs M&A €338 million ($447 million) ISOLUX WAT CORSÁN-CORVIAM CMS-Despacho Albiñana & Suárez de Lezo Uría & Menéndez, Madrid, Rafael García Llaneza M&A $400 million Hellman & Friedman MMC Capital agreed to sell Vertafore Simpson Thacher & Bartlett Debevoise & Plimpton, New York, Seth Rosen, Lawrence Cagney M&A $3.4 billion Noble Energy Patina Oil & Gas Corporation Skadden Cravath, Swaine & Moore, New York, Stephen Gordon, Sharon Mendelson, Ellen Kandel-Burg M&A £169 million ($314 million) Kingston Communications Omnetica Group Ashurst Allen & Overy, London, David Lewis, Daniel Lewin M&A £101m ($189 million) Hicks Muse Secondary buyout of Jimmy Choo KPMG Deloitte & Touche, London, Gordon Dootson, Catherine Hall; Travers Smith, London, Victoria Nicholl M&A £203 million ($378 million) Hammerson Barclays Bank agreed to sell its 50% interest in West Quay Shopping Centre Herbert Smith Allen & Overy M&A $35 billion Sprint Corporation agreed to merge with Nextel Communications Nextel Communications agreed to merge with Sprint Corporation Sprint Corporation was advised by Cravath Jones Day, New York, John Cornell; Paul, Weiss, Rifkind, Wharton & Garrison, New York, Jeffrey Samuels, John Harrell Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Financing for a public tender offer €12 billion ($15.7 billion) Telecom Italia JP Morgan Gianni, Origoni, Grippo & Partners, Rome, Massimo Agostini Allen & Overy

The tax bill for 2005 was approved on November 13 2004 and published in the official gazette on December 1 2004. This new tax bill creates a new definition of "business profits", which excludes the payments that are subject to the Mexican withholding tax under domestic law. Before the law change, these concepts could have been exempt from withholding if they qualified as business profits in accordance with the tax treaties signed by Mexico and the commentary to the OECD Model Tax Convention.

With effect from January 1 2005 the amendments to the Polish Tax Code became effective, including that the tax authority is obliged, upon written request of the taxpayer, to issue binding advance tax rulings. A taxpayer that receives a ruling cannot be charged with any outstanding tax liability, provided that he conducted his transactions consistently with the tax authorities' interpretation of the tax law included in the ruling. The previously existing system of rulings had not offered such opportunity; the "old" rulings protected taxpayers against penalties but not against payment of the tax liability as such.

In 2004 tax authorities around the world increased their focus on transfer pricing and tax compliance, the European Court of Justice continued to exert pressure on EU member states' tax systems and the US Congress passed significant corporate and international tax reform. Simon Briault gets the views of tax professionals as they peer into their crystal balls for what 2005 has in store.