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DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 26/05/01 acquisition $675 million Old Mutual, UK St Paul Companies Inc n/a Sullivan & Cromwell, Bill Indoe, Sara McLeod, Terry O'Reilly Weil Gotshal & Manges, New York, Kenneth Heitner, Scott Sontag 25/05/01 merger £28 billion ($39.9 billion) Halifax Bank of Scotland n/a Herbert Smith, London, Bradley Phillips, Nikol Davies Linklaters & Alliance, London, Tom Scott n/a 21/05/01 joint venture EUR4.5 billion ($3.9 billion) n/a n/a Matra BAe Dynamics, Alenia Marconi Systems n/a n/a BAe Systems, Linklaters & Alliance, London, Ian Bowler, Dominic Winter, Elliot Weston; KPMG, London, Caroline Austin, Alex Priestley. EADS, Clifford Chance, London, David Harkness, Alice Gamble. Alenia Marconi Systems, Ashurst Morris Crisp, London Richard Palmer, Kate Eveleigh 11/05/01 global offering $1.8 billion Merrill Lynch, UBS Warburg SunAmerica Life Insurance Company GIC-backed notes and auction market equity securities AIG SunAmerica Global Financing n/a Davis Polk & Wardwell, New York, Po Sit, Michael Farber, Roy Caner O'Melveny & Myers, Los Angeles, Dean Weiner 09/05/01 rights issue £5.9 billion ($8.4 billion) n/a BT (British Telecommunications) n/a Linklaters & Alliance, London, Tom Scott, Mark Kingstone, Stephen Pevsner, Lynne Walkington; Shearman & Sterling, London, Bernie Pistillo; In-house, John Clark, Simon Coward n/a n/a 08/05/01 acquisition $408 million Cypress Group, US, Carlyle Group, US, holding company MedPointe Capital Partners Carter-Wallace Inc, Pharmaceutical division n/a Sullivan & Cromwell, New York, Ron Creamer, John Sweet Simpson Thacher & Bartlett, New York, Charles Rappaport, Adam Rosenzweig n/a 08/05/01 acquisition $739 million Church & Dwight, US, Kelso & Co, US, holding company Armkel Llc consumer brands of Carter-Wallace Inc n/a Sullivan & Cromwell, New York, Ron Creamer, John Sweet Gibson Dunn & Crutcher, Dallas, Jeff Trinklein, Misty Burns; Skadden Arps, Slate Meagher & Flom n/a 07/05/01 acquisition $6 billion Valero Energy Corporation Ultramar Diamond Shamrock n/a Jones Day Reavis & Pogue, Cleveland, Carl Jenks; Washington, Candace Ridgway; Wachtell, Lipton, Rosen & Katz, New York, Jared Rusman 04/05/01 demutualization and flotation £4.2 billion ($5.99 billion) n/a Friends Provident Friends Provident plc Herbert Smith, London, Ross Fraser, Howard Murray, Zoe Brown; PricewaterhouseCoopers, London, Lindsay J'afari-pak, Peter Hoye n/a n/a 03/05/01 acquisition £4.8 billion ($6.8 billion) Vodafone Group Plc BT interests in Japan Telecom, J-Phone, Airtel BT Bird & Bird, London, Richard Ward; BT in-house, London, John Clark, Simon Coward Linklaters & Alliance, London, Andrew Beverley, David Blumenthal; Sullivan & Cromwell 30/04/01 acquisition $1 billion Maxtor Corp Quantum HDD Quantum Corp Wilson Sonsini Goodrich & Rosati, Palo Alto, Ronald Roth Gray Cary, Palo Alto, Dave Plewa 25/04/01 security offering £1.2 billion ($1.7 billion) n/a equity and debt securities in Cazenove n/a Slaughter and May, London, Howard Nowlan n/a n/a 24/04/01 acquisition £150 million ($214 million) Siemens Mannesmann UK Vodafone In-house, Klaus-Peter Husgen; KPMG, Anneli Collins In-house, Regine Nowack, Stephen Beckett; Norton Rose, London, Christopher Norfolk, Rupert Shires 11/04/01 acquisition £130 million ($185 million) Wilson Connolly Holdings plc Wainhomes n/a KPMG Liverpool/Manchester, Malcolm Edge; McGreggor Donald KPMG, London, Margaret Stephens, Gary Jones; Wragge & Co, London, Jeremy Millington 05/04/01 acquisition $1.5 billion Suiza Foods Corp Dean Food Co n/a Kirkland & Ellis, Chicago, Keith Villmow Hughes & Luce, Dallas, Ronald Kerridge; 04/04/01 acquisition £810 million ($1.15 billion) Bass Plc Posthouse Hotel chain Compass Group Freshfields, London, Tim Crossley, Francis Sandison Linklaters & Alliance, London, Charles Hellier, Kathryn Farthing

Sales of goods manufactured in the US or other countries are still the most common way to cover the Mexican demand for raw materials or already processed products. However, in the last few decades, the incorporation of subsidiaries in Mexico has been changing this situation – the product is available in Mexico for the Mexican client or even for export activities. Further, over the last few years, a different approach has entered the arena – the just-in-time idea – through which inventories are owned by a non-resident entity in a warehouse in Mexico. The first tax question for just-in-time holdings is that of whether a permanent establishment exists when the non-resident has a warehouse in Mexico to deliver goods to its clients, but closes every sale directly with the customer from abroad. The author takes the view that no permanent establishment has been created and therefore no income tax should be paid in Mexico.

Finland levies asset transfer tax at a rate of 1.6% of the relevant market value on the transfer of Finnish securities. Excluded from asset transfer taxation are:

Does article 17 of the OECD model convention have its basis in outdated and discriminatory assumptions about artistes and athletes? Hold on to your hats for a whistle stop tour of its development, its lack of fit with the modern world and reasons for its repeal. By Joel Nitikman, Fraser Milner Casgrain LLP, Vancouver

Germany’s Federal Ministry of Finance has changed taxation on the sale of and disregarded a recent court ruling for convertible and exchangeable bonds. By Florian Schultz, Linklaters Oppenhoff & Rädler, Frankfurt

US Treasury Secretary Paul O'Neill has revealed that he wants to abolish corporation tax. In an interview with the London-based Financial Times, O'Neill states that in the future he would like to eliminate corporate income tax and capital gains tax for companies. The changes would not be considered until President Bush's $1.35 trillion tax cut has been enacted and social security has been looked at. In the interview, O'Neill refers to the present tax system as ?an abomination? and claims that George W Bush is also keen to change the tax code. Corporate taxes account for around 10% of federal revenues and O'Neill proposes to make up the lost revenue by increasing personal income taxes.

The Thai Ministry of Finance is to make the process of claiming VAT refunds quicker and easier for companies that use local raw materials, according to a report in Bangkok-based newspaper Krungthep Turakij. New regulations designed to extend the refunds to more manufacturers will ultimately apply to all industries, but will be introduced for the textile industry first because it is a major export earner for the country.

US law firm Atheimer & Gray has established a tax group in London by poaching the head of tax from Fox Williams. Vishvas Kanji is joining Atheimer & Gray in June this year, having been a partner at Fox Williams since 1996.

KPMG Meijburg in Amsterdam has expanded its transfer pricing group by hiring a senior manager from PricewaterhouseCoopers. Eduard Sporken joins the firm on June 1. Sporken had not been thinking of leaving PricewaterhouseCoopers when KPMG approached him before Christmas. However, he was attracted to the opportunity to specialize in transfer pricing. He had also worked with KPMG in the past and knew people there.

The Dutch government has decided to issue a new proposal for measures against dividend stripping. Dividend stripping refers to a transaction in which a shareholder transfers its right to receive a dividend to another taxpayer prior to the declaration of the dividend. In most cases, the underlying reason is that the transferor is not in a position to offset the (Dutch) dividend withholding tax against personal or corporate income taxes, whereas the transferee is allowed to offset this tax.