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Jeffrey Shafer and Ian Caines, of Blake, Cassels & Graydon, explain how the recent protocol to the Canada-UK tax treaty could induce a change in the way taxpayers approach disputes covering the two jurisdictions.

As the planning opportunities for avoiding, deferring or sheltering taxable gain on asset dispositions continue to be curtailed through changes in tax law and administration, taxpayers have turned to partnership transactions to accomplish these goals. Michael Sabbah, associate at Wachtell, Lipton, Rosen & Katz, explains why new proposed IRS regulations could limit the use of these types of transactions.

The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations.

Morris Maroon has joined Rockwell Olivier as head of tax. He will work from the Sydney office, leading a team that advises businesses and professional advisers on all areas of Australian domestic and international tax law and also assists clients and accountants to resolve complex disputes with the Australian Tax Office (ATO).

Cristina Sampaio Cavalieri Teixeira has joined Hirashima & Associados as the partner responsible for leading the firm’s tax consulting department.

The Supreme Court of Appeal (SCA) handed down judgment in the matter of CSARS v Terraplas South Africa Proprietary Limited on 23 May 2014. The taxpayer contended its product’s classification, arguing for an import duty of 1.3%, instead of the 10% rate that the revenue authority imposed. Emil Brincker of DLA Cliffe Dekker Hofmeyr sheds light on the case.

Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Notes offering $4.5 billion IBM BNP Paribas Securities; Goldman Sachs; HSBC; JP Morgan; Mizuho; RBC Capital Markets Davis Polk & Wardwell - Michael Mollerus, Ethan Goldman Senior notes offering $800 million Comcel Trust Citigroup Global Markets; Credit Suisse Securities; Morgan Stanley Davis Polk & Wardwell - Lucy Farr; Walkers Milbank, Tweed, Hadley & McCloy Senior unsecured notes offering $350 million HCP Inc Goldman Sachs; JP Morgan Securities; Wells Fargo Skadden, Arps, Slate, Meagher & Flom Convertible senior notes offering $345 million Cepheid Morgan Stanley; Jefferies; Goldman Sachs Fenwick & West Davis Polk & Wardwell - Rachel Kleinberg, Catherine Paskoff Chang Convertible senior notes offering $300 million PDL BioPharma RBC Capital Markets; Wells Fargo Securities Gibson, Dunn & Crutcher Davis Polk & Wardwell - Lucy Farr, Juelle Gomes Senior notes offering $150 million Webster Financial Corporation Jefferies; Deutsche Bank Securities; Sandler O'Neill Wachtell, Lipton, Rosen & Katz Davis Polk & Wardwell - Samuel Dimon

A December 2013 opinion from the Federal Tax Attorneys’ Office in Brazil about whether remittances abroad should be taxed at source could be a change in reasoning rather than position

Peter Clark has joined Baker & McKenzie in Toronto as a partner in the tax department after the closure of Heenan Blaikie, his previous firm.

Finance ministers from France and Germany met in Paris today to discuss the future of the financial transaction tax (FTT).