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The lease rental securitization for London's Canary Wharf closed on June 6. Allen & Overy acted for Schroder Salomon Smith Barney, the arranger and joint lead manager, and Clifford Chance acted for Canary Wharf in structuring and documenting the £975 million ($1.47 billion) deal.

The internet is opening up a new world of opportunities for international tax planning and putting a premium on specialist advice

Hamburg's comdirect bank AG, the online banking subsidiary of Commerzbank AG, is to issue an initial public offering of euro790 million ($753 million) in bearer shares. Comdirect is the largest online broker in Europe. The shares were listed on the Neuer Markt segment of the Frankfurt Stock Exchange.

The Vodafone Airtouch Group has sold Orange to France Telecom for £25.1 billion ($37.9 billion). The deal will be settled by a cash payment of £13.8 billion and the issue to Vodafone of 129.2 million France Telecom shares valued at £11.3 billion.

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.

Fenwick & West LLP

Cahill Gordon & Reindel

Freshfields and Bruckhaus Westrick Heller Lober are to merge on August 1. The merged firm will be known as Freshfields Bruckhaus Deringer, and will combine Freshfields' international experience and local practices around the world with Bruckhaus' corporate and financial practice in Germany, Austria and central Europe.