Search results for

Ernst & Young's US business confirmed on May 24 2004 that federal prosecutors are again investigating its tax services. The investigation follows a $15 million civil settlement in 2003 between the big-four firm and the US Internal Revenue Service. The US attorney for the southern district of New York, the Manhattan branch of the Department of Justice, has a grand jury looking at allegations that Ernst & Young improperly sold tax products to clients.

On April 23 2004 the Italian Ministry of Finance issued an ad hoc Decree implementing the necessary detailed rules to make the so-called transparency regime fully effective. Indeed, articles 115 and 116 of the Italian Tax Code (ITC) provide for an optional regime pursuant to which a resident corporation, under certain conditions, can be deemed as transparent like a partnership, for the purpose of the 33% corporate tax (the Transparent Corporation).

Sed Crest finds out why tax executives are under increasing pressure in the region, which firm they think has the best brand and whether law firms or professional services firms are winning more of the tax-services dollar

The remuneration schemes for partners in law and accounting firms in Australia has come under intense scrutiny after KPMG agreed a A$100 million ($69 million) payout to the Australian Taxation Office (ATO) for allegedly breaching anti-avoidance tax rules.

The Mumbai Tribunal in Maharashtra State Electricity Board v. DCIT (83 TTJ 325), examined applicability of the old India-UK Double Tax Avoidance Treaty (DTAA), which was substituted by new DTAA in 1994, to fees received by a UK-based firm of solicitors for legal services provided to an Indian company.

The Canadian Supreme Court decision last year in Markevich v. The Queen affirmed that federal limitation periods may limit collection of long-outstanding tax debts. However, many advisers speculated that the taxpayer's victory would be temporary at best given the Crown's public requests that the law be changed.

Peter Costello described his ninth - and perhaps final - Budget as designed to keep Australia's economy strong. He may well have added that it also strengthens the re-election chances of the coalition government. In a clear pitch to middle Australia, the treasurer announced increased payments to families, increased superannuation government co-contributions, and personal tax cuts that will ensure that the majority of Australian workers pay a top tax rate of 30%. He also announced spending initiatives in the key sensitive areas of health, education and aged care.

The draft Transfer Pricing Code of Conduct will improve how the EC Arbitration Convention works. Heinz-Klaus Kroppen and Stephan Rasch of Deloitte assess the progress made by the JTPF and the impact of the draft Code on new EU member states

Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A A$5 billion ($3.5 billion) Singapore Power TXU Corporation agreed to sell its Australian assets Minter Ellison, Melbourne, Mark Green, Alan Kenworthy McDermott Will & Emery, Chicago, Lawrence Kemm; Baker & McKenzie, Melbourne, Ian Kellock M&A $10.5 billion Citizens Financial Group, a wholly-owned subsidiary of The Royal Bank of Scotland Charter One Financial Davis Polk & Wardwell, New York, Kathleen Ferrell Wachtel, Lipton, Rosen & Katz, New York, Jared Rusman, Adam Chinn M&A $2.1 billion Pioneer Natural Resources Company Evergreen Resources Vinson & Elkins, Dallas, Thomas Crichton, James Meyer, David Peck Baker Botts, Houston, Gray Jennings, Alia Vinson M&A $4.3 billion Kohlberg Kravis Roberts & Co The DIRECTV Group agreed to sell PanAmSat Corporation Simpson Thacher & Bartlett, New York, Steven Todrys, Rob Holo The DIRECTV Group was advised by Weil, Gotshal & Manges, New York, Marc Silberberg M&A $6.98 billion Sun Trust Banks National Commerce Financial Corporation Skadden, Arps, Slate, Meagher & Flom, New York, Mitchell Solomon; King & Spalding, Atlanta, Robert Woodward Wachtel, Lipton, Rosen & Katz, New York, Jared Rusman, Adam Chinn M&A Undisclosed CCL Industries agreed on a joint venture with RAR to create COLEP CCL Industries agreed on a joint venture with RAR to create COLEP CCL Industries was advised by Linklaters, Lisbon, Tânia Almeida Ferreira; Madrid, Nicolas Martin; London, Neal Todd, Natalie Coope; Luxembourg, Paul Tulcinsky; Frankfurt, Boris Bergemann RAR was advised by Telles de Abreu, Lucena e Associados M&A £673 million ($1.18 billion) Funds advised by BC Partners Baxi Group KPMG, London, Paul Megson, Mark Wardle PricewaterhouseCoopers, London, John Holt, Dave Saunders M&A $1.26 billion Citigroup Principal Financial Group agreed to sell Principal Residential Mortgage Skadden, Arps, Slate, Meagher & Flom, New York, Stuart Finkelstein Principal Financial Group was advised by Kirkpatrick & Lockhart, Pittsburgh, Stephen Barge M&A $993 million Siemens Véolia Environnement agreed to sell US Filter Corporation Shearman & Sterling, New York, Laurence Bambino, John Cannon Cleary, Gottlieb, Steen & Hamilton, New York, Deborah Kurtzberg M&A $100 million Rita Medical Systems Horizon Medical Products Heller Ehrman White & McAuliffe, Menlo Park, Mark Windfield-Hansen, Renee Deming King & Spalding, Atlanta, Herschel Bloom M&A $610 million Metavante Corporation First Data Corporation Weil, Gotshal & Manges, New York, Helyn Goldstein Davis Polk & Wardwell, New York, Laura Barzilai M&A $1.9 billion Marsh & McLennan Companies Kroll Wachtell, Lipton, Rosen & Katz, New York, Deborah Paul Cleary, Gottlieb, Steen & Hamilton, New York, Jason Factor, Yoav Wiegenfeld Type of deal Value Issuer Lead managers Adviser to Issuer Adviser to lead managers Bond issue ?10 billion ($11.87 billion) Northern Rock Barclays Capital and HSBC Allen & Overy, London, Mark Brailsford, Amrit Dehal Freshfields Bruckhaus Deringer, New York, Yaniv Emanuel Bond issue £120 million ($212 million) Ashtead Group Citigroup and Banc of America Slaughter and May, London, Graham Earls Shearman & Sterling, London, Michael McGowan, Bernie Pistillo, Leanne Ingeldew, John Peterson Notes issue $375 million OJSC Severstal Citibank Global Markets Clifford Chance, New York, David Moldenhauer Linklaters, New York, Stephen Land, Matt Welsh Securitization £4 billion ($7.05 billion) Holmes Financing (No. 8), the issuer on the eighth securitisation under the Abbey National master trust Barclays Capital, Lehman Brothers and UBS Investment Bank Slaughter and May, London, Charles Goddard Allen & Overy, London, Mark Brailsford, Amrit Dehal

The Brazilian economy could be the loser from the increase in the tax burden on the import of services, warn Gustavo Haddad and Bruno Carramaschi of Goulart Penteado, Iervolino e Lefosse Advogados, in cooperation with Linklaters