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Doug Stainton Group tax director, Diageo

There has been debate over the past two years as to how, if at all, the UK's double tax relief system should be modernized. The general consensus appeared to be that only minor changes were necessary, and that the basic principles should be retained unchanged. In particular, moves to an exemption method, or to onshore pooling of tax credits, were considered to be no improvement on the status quo. It was therefore a major shock when it became apparent immediately following the UK budget that one of the most widely used methods of maximizing double tax relief, which had been implicitly accepted by the UK Inland Revenue for many years, was to be abolished.

On May 15 2000, the US Internal Revenue Service (IRS) released Announcement 2000-48, containing additional guidance for financial institutions wanting to act as qualified intermediaries (QIs). The announcement supplements Rev. Proc. 2000-12 that set out the final version of the model QI agreement.

Corporate taxation – stock options

Spain has included within its corporation tax law an anti-abuse clause based on article 11 of the EU Merger Directive. But difficulties in translation have caused problems. Jesús López Tello of Uría Menéndez, Madrid describes the outcome

Dewey Ballantine LLP

Fenwick & West LLP

Granada Media has published a pathfinder prospectus for a global offering of shares to raise approximately £1.2 billion ($1.8 billion) to £1.5 billion of new capital, net of expenses.

Sanford C Bernstein & Co, a private US money management firm, has been acquired by Alliance Capital Management and Alliance Capital Management Holding, subsidiaries of French insurance and asset management group, AXA. The acquisition price is approximately $3.5 billion in cash and stock.

Communications company NTL has completed its £8.2 billion ($12.4 billion) acquisition of the consumer division of Cable & Wireless Communications. The acquisition was funded with a mixture of cash, shares and assumed debt.