Search results for

In May 2004, the German Federal Ministry of Finance issued an updated and revised version of the comprehensive regulations that guide the tax authorities in their application of the Foreign Transactions Tax Law (Aussensteuergesetz - AStG). The revised regulations (published in the German Federal Gazette Part I 2004, special issue 1/2004) supersede those of December 1994 and reflect subsequent legislation and high court decisions.

The draft Finance Bill for 2005 provides for an amendment to the French Tax Code with respect to the tax consequences of the transfer by a French company of its registered office to another EU member state.

Draft legislation was recently released by the Canadian Department of Finance to implement many of the measures announced in the government's March 23 2004 Budget. Certain changes to the rules affecting income trust structures featured prominently in the Budget. The September 16 2004 draft Budget legislation contains some important changes from the measures announced in the Budget.

The American Jobs Creation Act is the most comprehensive corporate tax law in the US for almost 20 years. Taxpayers need to get to grips with what it means for their business, urge Margie Rollinson, Michael Mundaca and David Benson, of Ernst & Young

On September 6 2004 Law 25.924 introduced a transitory regime aimed at promoting investments in industrial activities and infrastructure during the next three years.

The US' Internal Revenue Service (IRS) released its guidance priority list with 276 items for 2004-2005 in July 2004. Nicholas DeNovio, deputy chief counsel (technical) at the IRS, is responsible for overseeing this programme in collaboration with the Office of Tax Policy (OTP). DeNovio outlined the international priorities within the busy guidance programme to Sed Crest.

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A $1.25 billion Cendant Orbitz Skadden, Arps, Slate, Meagher & Flom, New York, James Tandler Latham & Watkins, Chicago, Christopher Bennett, Mia DiBella, Brad Faris, Tim FitzSimons M&A Undisclosed Ty Warner Hotels & Resorts Las Ventanas al Paraiso Resort Baker & McKenzie, Chicago, John McLees, John McDonald; Miami, James Barret; Juarez, Jaime Gonzalez-Bendiksen Thompson & Knight; Andrews Barth & Harrison M&A £335 million ($432 million) Punch Taverns agreed to acquire Innspired Group from Alchemy Partners Innspired Group Slaughter and May Macfarlanes, London, Elizabeth Sherwood; Nabarro Nathanson, London, Michael Cant M&A $160 million Yahoo! Musicmatch Skadden, Arps, Slate, Meagher & Flom, Los Angeles, Moshe Kushman, Sandra Strassner Paul Hastings Janofsky & Walker M&A $130 million European Aeronautic Defence and Space Company J F Lehman & Company and Tailwind Capital Partners Kaye Scholer; Clifford Chance Jones Day, London, Blaise Marin-Curtoud M&A ?3.6 billion ($4.5 billion) Lone Star Hypo Real Estate Group agreed to sell a portfolio of real estate loans Mayer, Brown, Rowe & Maw, Frankfurt, Ingo Kleutgens Freshfields Bruckhaus Deringer, Frankfurt, Wilfried Schaefer, Jan Brinkmann M&A $913 million ARM Holdings Artisan Components Davis Polk & Wardwell, New York, Kathleen Ferrell; Menlo Park, Rachel Kleinberg Wilson Sonsini Goodrich & Rosati, San Francisco, David Gerson M&A C$1.4 billion ($1.1 billion) Rogers Wireless Communications Microcell Télécommunications Stikeman Elliot, Montreal, Robert Hogan, Christian Meighen; Pillsbury Winthrop, New York, David Falck Fasken Martineau DuMoulin, Toronto, William Bies M&A ?320 million ($409 million) Candover Partners UCB SA agreed to sell its films business Ashurst, London, Richard Palmer, Kirsty Price Beachcroft Wansbroughs M&A $677 million Fortress Investment Group Stelmar Shipping Shearman & Sterling, London, Bernie Pistillo, Suzette Batista, Leanne Ingledew Kirkland & Ellis, New York, Greer Phillips, Sara Zablotney M&A ?800 million ($1.02 billion) Caja de Ahorros del Mediterráneo StrateStrategic alliance between CAM and AEGON to develop the bank assurance business through Mediterráneo Vida and manage the assets contributed by the parties. Uría & Menéndez, Madrid, Rafael García Llaneza Garrigues Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Bond issue ?180 million ($221 million) Fondiaria-SAI Mediobanca-Banca di Credito Finanziario Ashurst, Milan, Stefano Serbini Skadden, Arps, Slate, Meagher & Flom, London, Tim Sanders Notes issue $250 million Human Genome Sciences Merrill Lynch and Credit Suisse First Boston Piper Rudnick, Baltimore, Joseph Langhirt Shearman & Sterling, Washington, Frank Strong, Kristen Garry Notes issue $736 million Calpine Corporation Deutsche Bank Securities Covington & Burling, Washington, William Paul; New York, Alison Wang Davis Polk & Wardwell, New York, Lucy Farr, Laura Iannucci Financing ?497 million ($635 million) TDR Capital The Royal Bank of Scotland provided the financing for TDR Capital's acquisition of Algeco Gide Loyrette Nouel Allen & Overy, Paris, Patrice Couturier

The countries of the Gulf Cooperation Council (GCC) have agreed to levy value-added tax (VAT) on tobacco and its by-products from the middle of 2005. The GCC states of Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the UAE also intend to gradually expand VAT collection to cover consumer goods.

Oman's Ministry of National Economy is working on a new income tax law that would consolidate the existing legislation (originally issued in 1981), simplify tax procedures and speed up tax assessments. Interested parties have submitted recommendations on the interpretation of permanent establishments, transfer-pricing rules and the need for an official English version of the tax laws.

During the ECOFIN meeting of September 10 and September 11 2004, the European Commission presented a non-EU-wide solution for profit determination rules for cross-border companies. This new approach, which is not yet a formal proposal and which arises from the failure to achieve unanimity at the EU level for further harmonization of EU member states' tax laws, will first be studied by working groups.