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  • The problem of surplus advance corporation tax has long been the bane of the UK multinational’s life. Now the ACT system is set for abolition. Murray Clayson of Freshfields, London considers the consequences, and the likely form of a successor shadow system
  • After losing out to its Asian neighbours in attracting a number of big investment projects, the Australian government has announced a new investment programme which includes tax incentives. Ian Dinnison, of KPMG, Melbourne reports on the new attractions
  • Zeneca is to acquire a US fungicide business owned by Japanese chemicals company Ishihara Sangyo Kaisha. Zeneca will acquire ISK Biosciences and the international distribution rights outside Asia-Pacific. The deal is valued at $500 million. Davis Polk & Wardwell in New York is acting for Zeneca, with advice from tax partner Mario Verdolini and assistant Avrohom Gelber. KPMG is also advising.
  • Arthur Andersen in Zurich provided tax advice on the merger of Zurich Insurance and the financial services division of BAT Industries (for prior coverage see ITR Dec/Jan 1998, p6). Tax partners Peter Athanas and Maja Bauer-Balmelli worked on the Zurich Insurance side of the deal.
  • Société Générale has acquired Hambros Banking Group from Hambro in a deal worth £300 million ($483 million). The banking group includes Hambros bank and its subsidiaries and associates, together with shareholdings in certain other companies. Société Générale was advised by tax partner Francis Sandison at Freshfields in London. Norton Rose acted for Hambro. Tax advice came from partner Louise Higginbottom and assistants Dominic Stuttaford, Nick Stretch and Mark Middleditch.
  • Virgin has sold Virgin Radio to Ginger Media Holdings for £81 million ($130 million). Mark Joscelyne from law firm Olswang advised Ginger Media Holdings on tax. UK City firm Macfarlanes advised Virgin. Partner Ashley Greenbank was responsible for tax advice.
  • The US natural gas utility KN Energy is to acquire gas pipeline company Midcon Corporation from Occidental Petroleum. The deal is worth $3.49 billion. KN has already spent $1.5 billion on acquisitions since 1989. The transaction will provide KN with more than 41,600 kilometres of pipeline in 15 US states, and boost annual revenue to $4.7 billion.
  • US bank First American has made a successful $2.7 billion stock bid to acquire Deposit Guaranty. Wachtell, Lipton, Rosen & Katz in New York is acting for First American. Tax partner Adam Chinn is dealing with tax issues raised by the bid.
  • MascoTech is set to merge with TriMas Corporation, a manufacturer of industrial products. The transaction is valued at approximately $900 million. MascoTech already owns 37% of TriMas. The merged organization will have a combined sales volume of $1.6 billion.
  • The IRS has announced that it will not appeal against the US Tax Court's decision in the SDI Netherlands BV v Commissioner case. The court found that royalty payments made by the taxpayer for the use of software in the US, to a related company in Bermuda did not qualify as US source income. The finding was based on the fact that the royalty payments from SDI USA passed through SDI Netherlands before they reached the Bermuda company.