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Glaxo Wellcome and SmithKline Beecham have proposed a merger that would create the world's largest pharmaceutical group and the world's third-largest company after General Electric and Royal Dutch/Shell. The deal is worth £100 billion ($160 billion).

The US Internal Revenue Service has signalled its intention to limit the tax advantages available to some hybrid branches. Joseph DeCarlo of Price Waterhouse LLP, and Alan Granwell and Dirk Suringa of Ivins, Phillips & Barker, Washington DC report

For the first time, Deloitte Touche Tohmatsu has released its worldwide tax fee income results.

An international group of investigators is said to be examining the tax affairs of global media group News Corporation. The rumoured investigation is thought to involve senior tax investigators from tax authorities in the UK, US, Australia and Canada. A spokesman for the UK's Inland Revenue would neither confirm nor deny the story, adding that the affairs of individual companies are never discussed. However a prominent international tax lawyer has told International Tax Review that even if there is as yet no investigation, the adverse publicity will probably ensure one.

Scottish Equitable has disposed of Aegon Financial Services Group to the UK's Life Assurance Holding Corporation for an undisclosed sum.

EC Tax Law

The entry into force in the US, on January 1 1997, of the IRS's final regulations under Section 301.7701 of the Internal Revenue Code (the so-called check-the-box regulations) requires a new analysis of the classification of Spanish legal entities.

Russia's tax treaty programme continues to evolve rapidly. Russian treaty negotiators have been extremely successful in modernizing Russia's treaties, and as a result 17 new double taxation conventions came into force during 1997.

By virtue of article 115 quinquies of the French tax code, after-tax profits realized by foreign companies in France (especially through a French branch) are deemed to be distributed to non-French tax resident partners, and are subject to a 25% branch tax (with possible limitation or exemption, depending on the applicable tax treaty).

As part of its April 26 1995 technical bill of proposed amendments to the Canadian Federal Income Tax Act, Canada's Department of Finance released sweeping changes to the definition of, and rules relating to, the concept of taxable Canadian property (TCP).