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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

The publication of the implementation rules for advance pricing agreements is a momentous step for transfer pricing in China, believe Spencer Chong and Joanne Su of PricewaterhouseCoopers

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

In an interview with International Tax Review, John Sanders, the international tax counsel of the government of Aruba, has criticized the EU's Code of Conduct on Business Taxation as unfair on jurisdictions that are affiliated to EU member states.

The government of the Netherlands has clarified the rules on how fiscal unities should allocate tax losses to subsidiaries when they leave the group. Joop Wijn, the Dutch state secretary of finance, on October 1 2004 issued a decree that answers taxpayers' queries on the fiscal unity rules first introduced on January 1 2003.

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.

The Israeli parliament gave its initial approval on October 18 2004 to a plan to lower capital gains taxes on foreign securities from 35% to 15%. The planned tax reduction must still pass through two further votes in parliament later this year and will go into effect in 2005 if it is approved.

Hugo Chavez, Venezuela's president, announced a sharp rise in the royalty tax on multinational oil companies on October 10 2004. The tax increase from 1% to 16.6% per barrel of oil was effective immediately and affects all foreign oil companies operating in the southwestern Orinoco region of Venezuela. The rate rise is expected to raise an annual $1.27 billion in additional tax revenues.

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