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International tax attorney Daniel M Berman has left Sutherland Asbill & Brennan to join Thelen Reid & Priest as a partner in the firm's Tax, Benefits, Trusts and Estates department in Washington, DC.

Stock option programmes have become a standard part of the compensation package for a wide range of employees in multinational corporations. A recent decision by the First Chamber of Germany's highest tax court reaffirms the position consistently taken by German courts and tax authorities that individuals receiving employee stock options recognize income when the options are exercised, not when they are granted, at least where the option is non-marketable (decision dated January 24 2001, docket no I R 100/98).

After years of international criticism over the lack of a transfer pricing regime, the Netherlands is finally codifying its arm’s-length principle. Proposed documentation requirements increase the administrative burden, so companies should review their arrangements well in advance. Eduard Sporken, KPMG Global Transfer Pricing Services, Amstelveen

KPMG's German law firm, KPMG Treuhand & Goerdeler GmbH, has merged with BBLP alliance member BBLP Beiten Burkhardt Mittl & Wegener. The merger will be effective from January 1 2002 and the combined firm will go by the name of KPMG Treuhand Beiten Burk hardt. The decision poses questions about the future of other BBLP alliance members, Meyer Lustenberger, Moquet Borde & Associes and Pavia e Ansaldo.

Singapore has announced a series of tax measures aimed at helping ailing companies through the economic downturn. Deputy Prime Minister Lee Hsien Loong announced the country's second tax package this year, worth around $11.3 billion, in parliament on October 12 2001. The package includes rebates for individuals and corporations as well as property rebates and a reduction in stamp duty rates. Announcing the measures Lee explained: ?We want to encourage enterprise, because the way to recover is for the private sector to create new opportunities and generate more wealth. We also want to reduce business costs so that business can stay afloat and minimise job losses.?

Within the EU, proposals by both the Swedish and UK governments for the optimum taxation of digitized products have fallen flat. A workable solution must be found – soon. By Andrew Ball, Deloitte & Touche, London

The epic trade war between the US and the EU continues, with the US refusing to accept a WTO ruling against its Foreign Sales Corporation (FSC) legislation. It is appealing against the WTO's August 20 decision in favour of the EU's claims that the act and its replacement, the Extraterritorial Income Exclusion Act (ETI) of November 2000, constitute an export subsidy that allows US exporters to save billions of dollars a year.

Australia and the US have amended their tax treaty. The treaty protocol was signed on September 27 after several years of lobbying by business groups. Under the terms of the protocol Australian companies will be able to repatriate their dividends back from their US subsidiaries tax free. The protocol is due to enter into force in January 2003 after both countries have formally ratified it.

DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 07/09/01 recommended offer £103 million ($146.59 million) Greene King plc Old English Inns n/a Pricewaterhouse-Coopers, London, Anthony Bennett Linklaters, London, Keith Wilson n/a 14/09/01 project finance $125 million Pacific LNG Shipping Ltd (PLS) n/a n/a n/a White & Case, Tokyo, Yasuo Igarashi, Miyuki Ueda, Eric Roose, Linda Ng n/a 17/09/01 outsourcing of property portfolio £2 billion ($2.84 billion) BBC n/a Land Securities Trillium n/a Linklaters, London, Jonathan Evans, Michael Hardwick, Victoria Garton, Liz Cole; WS Burness Freshfields Bruckhaus Deringer, London, Murray Clayson, Angela Savin; WS Brodies 27/09/01 disposal £1 ($1.42) O'Rourke John Laing Construction n/a Freshfields Bruckhaus Deringer, London, Francis Sandison, Simon Skinner Nabarro Nathanson, London, Lydia Simpson; RSMI Robson Rhodes, Helen Riley n/a 07/10/01 acquisition $4.7 billion AT&T Wireless Telecorp PCS n/a Cadwalader, Wickersham, & Taft, New York, Linda Swartz, Jeffrey Ashendorf, Alexander Anderson Wachtell, Lipton, Rosen & Katz, New York, Jodi Schwartz n/a 08/10/01 acquisition $777 million Clear Channel Communications Inc Ackerley Group Inc n/a Dewey Ballantine, New York Gordon Warnke, Joseph Pari, John Apadula, Devon Bodoh; Rubin, Winston, Diercks, Harris & Cooke in-house n/a 08/10/01 disposal $2.9 billion Northwest Natural Gas Co Portland General Electric Co Enron Corp n/a Thelen Reid & Priest, New York, Gregory Pavin, Robert Friedman, Laura Lee Mannino Vinson & Elkins, Houston, Edward Osterberg 09/10/01 acquisition $3.8 billion Royal Dutch / Shell Group; Saudi Refining Inc 44% stake in Equilon Enterprises Llc; 35% of Motiva Enterprises Llc Texaco Inc Weil, Gotshal & Manges, New York, Kenneth Heitner, Michele Jacobsen Vinson & Elkins,Houston, Edward Osterberg; Shell, Dale Erickson; White & Case, Washington, Bruce Davis n/a 11/10/01 acquisition $1.98 billion NBC unit of General Electric Co Telemundo Communications Group Inc n/a Paul, Weiss, Rifkind, Wharton & Garrison, New York, David Sicular Weil, Gotshal & Manges, New York, Martin Amdur, Mary Jean Potenzone, Martin Pollack, Nancy Tong, Michael Tingoli, Lillian Spiess n/a 17/10/01 MBO £200 million ($284.64 million) Kyndal International Limited, West LB JBB (Greater Europe) Jim Beam Brands Worldwide Inc n/a Weil, Gotshal & Manges, London, Gary Richards, Sarah Priestley; New York, Kim Blanchard McClure Naismith, Glasgow, George Frier; Chad Park 18/10/01 bond issue $310 million UBS Warburg shares of Yukos n/a n/a Clifford Chance, Moscow, Irina Dmitrieva; New York, David Moldenhauer, James Graham, London, Gerald Montagu, Douglas French n/a 18/10/01 acquisition $1.3 billion WellPoint Health Networks Inc RightChoice Managed Care Inc The Missouri Foundation for Health Lewis, Rice & Fingersh, St Louis, Lawrence Weltman Simpson Thacher & Bartlett, New York, Gary Mandel Michael Tingoli, Lillian Spiess Blackwell Sanders Peper Martin llp