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Under the Mexican Federal Fiscal Code (MFFC), in the case of a merger or spin-off, the transfer of ownership of stock or goods is considered a taxable event, unless certain requirements are met.

DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 01/08/01 acquisition ($1.6 billion) £1.1 billion Gallaher Group, financed by Dresdner Kleinwort Wasserstein, Goldman Sachs, Barclays Capital, HSBC 41.3% stake in Austria Tabak n/a Cerha, Hempel & Spiegelfeld, Vienna, Dr Albert Birkner, Edith Hlawati Gallaher - Simmons & Simmons, London; Fried Frank Harris Shriver & Jacobson, New York; Banks - Linklaters, London, Ian Bowler, Giles Horridge, Sulivan & Cromwell, New York n/a 06/08/01 proposed acquisition £2.8 billion ($4.08 billion) Valentia Telecom-munications Eircom Valentia Consor-tium Arthur Cox, Dublin, Caroline Devlin, Niamh Caffrey n/a Freshfields Bruckhaus Deringer, London, Francis Sandison, Tom Passingham; Washington, Claude Stansbury, Kevin Cunningham; Debevoise & Plimpton, New York, Gary Friedman; London, Peter Schuur; A&L Goodbody, Dublin, Peter Maher, Andrew Quinn 06/08/01 tax planning and merger implemen-tation $6.86 billion Schneider/ Legrand n/a n/a n/a Andersen Legal, Paris, Frederic Donnedieu de Vabres n/a 10/08/01 convertible bond issue $500 million South African Breweries n/a JP Morgan Securities, Cazenove & Co n/a Lovells, London, Lyndsey Bainton Linklaters, London, Martin Lynchehan, Simon Marks 21/08/01 acquisition undisclosed Dexia Banque Internationale à Luxembourg Ely Fund Managers Holdings Ltd n/a Wedlake Bell, London, Jack Harper Norton Rose, London, Jeremy Reynolds n/a 31/08/01 share sale $157 million Enterprise Oil Petrobras' UK interests Petrobras Herbert Smith, London, David Mogford, Neil Warriner CMS Cameron McKenna, London, Richard Croker n/a 04/09/01 acquisition $2.2 billion Royal Ahold Alliant Food Service Inc n/a Debevoise & Plimpton, New York, Bob Cubitto, Seth Rosen, Rafael Kariyev White & Case, New York, Mario Fulgieri n/a 05/09/01 development £204 million($297.39 million) The Moor House Limited Partnership Ltd n/a n/a n/a Herbert Smith, London, Isaac Zailer n/a 10/09/01 merger / acquisition $25 billion Hewlett-Packard Company Compaq Computer Corporation n/a Skadden, Arps, Slate, Meagher & Flom, New York, Stuart Finkelstein, Kathy Bristor, Melissa McCann, Patrick Chu Wilson Sonsini Goodrich & Rosati, Palo Alto, Ivan Humphreys, David Gerson, Eileen Marshall n/a 10/09/01 merger $4.2 billion C-MAC Industries Inc Solectron Corporation n/a Stikeman Elliott, Montreal, Frederic Harvey, Luc Bernier; Davis Polk & Wardwell, New York, Kathleen Ferrell, Michael Mollerus Wilson Sonsini Goodrich & Rosati, Palo Alto, Ron Roth, Susie Morse; San Francisco, David Hasen; Osler Hoskin & Harcourt n/a 19/09/01 strategic alliance $1 billion Bristol-Myers Squibb ImClone Systems Incorporated n/a Davis Polk & Wardwell, Michael Mollerus, Kathleen Ferrell, Roy Caner Cravath Swaine & Moore, New York, Stephen Gordon n/a

For some while, the UK Inland Revenue has been committed to reviewing and updating the legislation covering the taxation of foreign exchange gains and losses (forex), financial instruments and corporate debt. A technical note was issued in November 2000 setting out suggestions for change and asking for comment, and at the time of the 2001 budget in March, a press release announced the publication of a further consultative document in the summer.

For some organizations, the value of their intangibles is a key element in the value of their brand. For others, intangible assets go unrecognized and unexploited. Find out how paying attention to intangibles can give your company a competitive advantage. By Thessa Mac, CMS Cameron McKenna, London

Creating a split among the US courts of appeal, the Ninth Circuit, in Boeing Co v US, validated Treasury Regulations section 1.861-8(e)(3) when it held that total research and development (R&D) costs must be allocated against export sales in computing the combined taxable income (CTI) of a FSC or DISC. The Boeing decision means that the appeals courts have now ruled once in favour of, and once against, taxpayers with regard to the proper allocation of R&D on unsuccessful or unexported products.

Latham & Watkins and Stibbe Paris have combined, effective October 1, giving the firm 95 lawyers in Paris and more than 200 attorneys throughout Europe. The combined firm will be known as Latham & Watkins.

International Tax Review, in association with KPMG, hosted its first Transfer Pricing Forum in Amsterdam on September 10 and 11. On the table for discussion were topics such as intangibles and intellectual property, e-commerce, APAs and dispute resolution, OECD and national developments, and practical transfer pricing strategies. The speaker line-up incorporated representation from in-house tax groups, professional advisory firms and law firms as well as the OECD.

The Israeli government is scrapping capital gains tax on foreign investments in local venture capital funds, following concerns about the disincentive that the former double taxation system created

The Chinese government is to levy environmental taxes and encourage private and overseas investment in environmental projects, according to a senior official at the State Environmental Protection Administration

Colin Masters has left his senior role at Coutts & Co to head a new Ernst & Young team, which will target entrepreneurial business with a variety of tax planning services