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  • Gerald Kafka and Rita Cavanagh joined Latham & Watkins' tax controversy practice in Washington DC on September 9 2003. Both partners left McKee Nelson to make the move and will concentrate on tax controversy litigation.
  • The Greek government announced plans to cut the corporate tax rate from 35 to 25 percent for investments over ?30 million on October 6 2003. The plans are part of its drive to attract more foreign investors and would run for 10 years.
  • Argentina's Congress passed a grain tax reform bill on October 1 2003 that angered members of the country's powerful agricultural industry. The bill will force grain exporters to pay income taxes based on the value of the product at the time of shipment rather than when the grains are sold. It aims to end the practice of selling grain at submarket prices to third-country tax havens, which allows exporters to declare much lower taxable earnings.
  • The Russian Taxes and Levies Ministry has detailed plans to improve corporate income tax collections. The ministry has prepared modifications to chapter 25 (corporate income tax) of the Russian Tax Code, which include changes to securities transactions, financial instruments and trust and other fixed-term transactions.
  • The Treasury recently finalized an amendment to its regulations on qualified cost-sharing arrangements (QCSAs) requiring that the deemed cost of stock options and other stock-based compensation be treated as a development cost to be shared with the participants of a QCSA along with the cash-based compensation of the employees involved in the development of intangibles subject to the arrangement. In many cases the effect will be to require greater cost contributions by the foreign participants in QCSAs and an increase in taxable income to the US participants. Taxpayers have rarely treated any part of the cost of stock options as a cost to be shared under a QCSA and have vociferously objected to the new rules.
  • The firm has promoted no fewer than seven tax specialists at its offices in Chicago and New York. Kevin Chen, Jack Bernstein, David Kung, Natalie Hoyer Keller, Gregory Gallagher, Kevin Coenen and Lee Allison became partners as of October 1 2003.
  • On September 30 2003 the European Court of Justice (ECJ) ruled that certain obligations imposed by Dutch law on companies formed abroad but having their principal place of business in the Netherlands are incompatible with EC law (case c-167/01, Inspire Art Ltd).
  • This note is aimed at providing a first preliminary overview of the main changes to the Italian tax system addressed by Law Decree 269 of September 30 2003, effective as of October 2 2003. This Decree must be converted into law by the Italian parliament within December 1 2003. Otherwise, it would be deemed as if it has never been enacted.
  • Anita Paddock and Chris Oates of Ernst & Young consider what the Australian experience may herald for corporate tax self-assessment elsewhere
  • Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A £426 million ($710 million) Macquarie Bank Saur agreed to sell South East Water Linklaters Freshfields Bruckhaus Deringer, London, Sarah Falk, Piers Curle M&A Undisclosed Sanlam Netherlands Holding Cornhill Insurance has agreed to sell its wholly owned subsidiary Merchant Investors Assurance Company Lovells, London, Lyndsey Bainton Slaughter and May, London, Graham Earles, Charles Goddard, Hilary Barclay M&A $14.8 billion Manulife Financial Corporation John Hancock Financial Services Simpson Thacher & Bartlett, New York, Steven Todrys Stikeman Elliot, Montreal, Robert Hogan; Sullivan & Cromwell, New York, Ronald Creamer M&A £2.51 billion ($4.16 billion) The Blackstone Group Scottish & Newcastle's managed retail business Simpson Thacher & Bartlett, London, Meredith Jones; New York, Gary Mandel Freshfields Bruckhaus Deringer, London, Sarah Falk, Peter Cosmetatos M&A £1.14 billion ($1.89 billion) Guardian Media Group Trader Media Group sold their remaining shares to Guardian Media Group who already owned 46% PricewaterhouseCoopers, Manchester, Jeremy Rayner, Steve O'Brien Eversheds, Birmingham, Janet Jones M&A $420 million Leonard Green & Partners LP FTD Latham & Watkins, Chicago, Joseph Kronsnoble, Geraldine Pellerin; Los Angeles, Laurence Stein Jones Day, Dallas, Dennis Drapkin; Chicago, Edward Purnell, William McKay M&A Undisclosed Hamsard 2353, the holding company of QS Group BeWise Group Jones Day Gouldens, London, Caitriona McGonagle BPE Solicitors Type of deal Value Issuer Lead managers Adviser to issuer Adviser to lead managers Bond issue £80 million ($134 million) Werretown Supermarkets Securitisations, a special purpose vehicle of British Land UBS Simmons & Simmons, London, Edward Troup Allen & Overy, London, Mark Brailsford, Vimal Tilakapala, Daniel Lewin Stock Offering ($133 million) Applied Films Corporation Citigroup Global Markets and CIBC World Markets N/A Simpson Thacher & Bartlett, New York, Rachelle Holmes Revolving credit facility £200 million ($333 million) House of Fraser HSBC Bank Slaughter and May, London, Steve Edge Linklaters, London, Stephen Taylor Securitization Undisclosed Home Credit Finance Credit Suisse First Boston Simmons & Simmons, Rotterdam, Peter de Brock Clifford Chance, Prague, Vlad Petrus; Amsterdam, Frank de Vos, Willem Trip, Philippe Steffens Securitization £210 million ($350 million) Priory Group Royal Bank of Scotland and Barclays Capital Clifford Chance, London, Michael Wistow, Etienne Wong, Judy Baker Skadden, Arps, Slate, Meagher & Flom, London, Tim Sanders, Sinton Clancy Securitization $1 billion Barclays credit card securitization of Q3 by the Gracechurch Trust Barclays Capital Clifford Chance, London, Stephen Shea, Etienne Wong, Alice Gamble, Alex Beattie; New York, John Lutz Weil, Gotshal & Manges, London, Andrew Norwood IPO $297.5 million Journal Communications Morgan Stanley & Co and Robert W. Baird & Co Foley & Lardner, Milwaukee, Jamshed Patel Simpson Thacher & Bartlett, New York, John Creed, Michelle Nadler Ingber Bond issue £300 million ($501 million) Hilton Group Deutsche Bank, Barclays Bank and Société Générale Slaughter and May Linklaters, London, Stephen Taylor