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Over the last few years Australian multinationals like James Hardie Industries have relocated outside Australia and others including Brambles and BHP Billiton have opted for dual-listed structures.

Larry Gafinowitz and Peter McCullough of Deloitte & Touche discuss the potential benefits for Australian and non-resident companies in the 2003 Budget

Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) M&A ?112 million Electra Partners Europe Electra Partners Europe to acquire Gardiner Group, Stentorius and JLD from Rexel Ashurst Morris Crisp, Paris, Christopher Potter; London, Richard Palmer, Ian Johnson Rexel was advised by Linklaters, Paris, Edouard Chapellier, Philippe Derouin; London, Ian Bowler, David Crowther, Simon Marks M&A $1.1 billion Malaysian International Shipping Corporation Neptune Orient Lines has sold American Eagle Tankers Paul, Weiss, Rifkind, Wharton & Garrison, New York, David Sicular, Joseph Mann In-house, Kelly Hughes; Akin Gump Strauss Hauer & Feld M&A $127 million Wand Partners, Banc of America Capital Investors, Greenhill Capital Partners, Brazos Private Equity Partners, 21st Century Group and Norwest Equity Partners Winterthur US Holdings is to sell its Republic group of companies Wand Partners advised by Skadden, Arps, Slate, Meagher & Flom, New York, Barnet Phillips, Angelo Ciavarella; the investor group was advised by Kennedy Covington Lobdell & Hickman, Charlotte, Warren Kean, Jared Mobley Dewey Ballantine, New York, Robert McDermott M&A ?1.05 billion ($1.2 billion) Candover Investments and Cinven Bertelsmann is to sell BertelsmannSpringer Clifford Chance Pünder, Düsseldorf, Uwe Schimmelschmidt Hengeler Mueller, Düsselforf, Martin Klein, Bernd Wirbel M&A $425 million Taylor Nelson Sofres The Interpublic Group of Companies Freshfields Bruckhaus Deringer, London, Jonathan Cooklin, Emma Bailey Cleary Gottlieb Steen & Hamilton, New York; Leslie Samuels, William L. McRae; Paris, Nicolas de Boynes M&A ?246 million ($287 million) SABMiller Birra Peroni Lovells, London, Daniel Friel; Rome, Fulvia Astolfi Maisto e Associati, Rome Paolo Ludovici M&A ?1.1 billion ($1.3 billion) Siemens ALSTOM Cleary, Gottlieb, Steen & Hamilton, London, Nikhil Mehta, Julian Hickey, Sophie Dworetzsky; Frankfurt, Daniel Weyde, Henning-Guenther Wind Lovells, London, Phillip Gershuny; Linklaters, Stockholm, Lars Jonsson M&A $500 million Valero Energy Corporation Orion Refining Corporation Baker Botts; Jones Day, Houston, Derek Green Vinson & Elkins, Houston, James Penny, Edward Osterberg M&A $1.1 billion Barclays Bank Banco Zaragozano Clifford Chance, Madrid, José Ignacio Jiménez Blanco, Roberto Grau, Maria Conejo Garrigues Abogados & Asesores Tributarios M&A $734 million USA Interactive Lending Tree Wachtel Lipton Rosen & Katz, New York, Jared Rusman, Joshua Holmes Weil, Gotshal & Manges, Houston, Paul Asofski; M&A $358 million Zoran Corporation Oak Technology Gray Cary Ware & Freidenrich, Palo Alto, David Plewa Wildman Harrold Allen & Dixon, Chicago, Michael Donovan, Joseph Bender M&A $133 million Aerojet-General, subsidiary of Atlantic Research Propulsion, subsidiary of Sequa GenCorp Slaughter and May Jones Day, London, Nick Thornton M&A ?756 million ($892 million) Chiron Corp Recommended cash offer for PowderJect Pharmaceuticals Allen & Overy; Sullivan & Cromwell Linklaters, London, Ian Bowler, Victoria Garton, Daniel Alexander, Cathya Djanogly; New York, Stephen Land, Valerie Leipheimer M&A £98 million ($160 million) Finning (UK) RAC is to sell Lex Harvey Freshfields Bruckhaus Deringer, London, Sarah Falk, Charlotte Jones, Kate Aubury Pincents, London, Ashley King-Christopher Type of deal Value Issuer Lead managers Adviser to issuer Adviser to lead managers Fundraising £200 million ($324 million) Thorstone Investment Grade Property Trust N/A Hammonds, London, Tracy Fisher, Omleen Ajimal N/A Notes Offering $350 million Kazkommerts International Credit Suisse First Boston Mayer, Brown, Rowe & Maw White & Case, New York, John Narducci Securitization £194 million ($317 million) Real Estate Capital, a special purpose lender established by NM Rothschild & Sons Merrill Lynch Clifford Chance, London, Tom Hawes Sidley Austin Brown & Wood, London, Graeme Harrower

On May 23 the US House of Representatives agreed $350 billion of tax cuts. The Senate gave its final approval to the proposals the following day. The Jobs and Growth Tax Relief Reconciliation Act of 2003 will lower the top tax rate on dividends and capital gains on the sale of assets held for over a year to 15% until 2008. At present, dividends are taxed at standard income tax rates, while the rate on most capital gains is 20%.

Basic International Taxation - gives insights into some of the nooks and crannies of international tax The author's preface declares Basic International Taxation to be a clarification of the basic principles of international taxation, and it succeeds very well. There are numerous books that look at subjects within the field of international taxation, but what Roy Rohatgi has produced is a work that spans the entire subject and places the various elements in context. For those who are looking for basic understanding, perhaps as a prelude to more in-depth analysis or as occasional practitioners of international tax, Basic International Taxation will be a useful addition to the bookshelf.

The EU has said it intends to create a public oversight system similar to the US’s to prevent Enron-type scandals, threatening to heighten the argument between the two over where an audit firm should register

US manufacturing multinational Ferro has hired Thomas Gannon as corporate vice president and CFO. Gannon will be responsible for overall financial management including accounting, tax and budgeting. Before joining Ferro he worked at Riverwood International, Rockwell International, Pilkington and PricewaterhouseCoopers. Ferro produces performance materials for industrial coatings and performance chemicals and has operations in 20 countries.

Companies operating in Europe might be able to offset overseas losses against other tax liabilities in the Europe Union if UK retailer Marks & Spencer (M&S) is successful in its appeal to the European Court of Justice (ECJ)

The US Internal Revenue Service has taken in a host of new talent, drawing key names from the private sector to boost its capabilities

Indian law firm Lexindia has launched a tax group in New Delhi attracting key big-four personnel and a corporate tax director