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  • Lam Kok Shang and Gan Hwee Leng of KPMG preview the introduction of goods and services tax (GST) in Malaysia from April 1 2015, comparing it with the equivalent regime in Singapore and explaining what taxpayers must do to prepare for the incoming changes.
  • The impact on companies of a string of senior-level departures from the Internal Revenue Service in the US earlier this year got another airing during the dispute resolution and controversy management panel of International Tax Review and TPWeek's 14th annual Global Transfer Pricing Forum in Washington, DC last week.
  • Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for US companies, particularly those in the highly-mobile pharmaceuticals sector. Whatever the motivation, inversions are in vogue. ITR’s special report looks at the knock-on impacts of the current wave of inversions, including shareholder pressure to consider an option they see their rivals pursuing and the possible inflammation of the tax morality debate in the US. We also bring you exclusive insight as to why Danaher is not looking to invert.
  • Hong Kong is an important financial, trading and service hub for China and Asia which is a result of very good infrastructure, highly effective financial markets and a highly competitive tax regime. Hong Kong has always aimed at minimising administrative burdens which results in a very simple and easy-to-handle tax regime that many countries would wish for. Thus, more complicated tax regulations including tax treaties or anti-avoidance regulations including transfer pricing have been kept to a bare minimum, if included at all.
  • Brian Birt has joined MHA MacIntyre Hudson in their London office, as a VAT manager. He has more than 15 years’ experience in indirect taxes and now manages his new firm's London and South East client portfolio.
  • The amnesty programme allows the waiver or reduction of penalties and interest relating to certain outstanding state tax obligations in a bid to increase tax revenue.
  • India has announced the adoption of IFRS converged standards for financial reporting and tax accounting standards for the computation of taxable income. Sai Venkateshwaran, partner and head of the accounting advisory services group at KPMG in India analyses the impact and challenges of these announcements.
  • Sponsored by Machado
    Provisional Measure 651/2014, enacted in July 2014 (MP 651/2014), re-established the Brazilian Special Regime for the Reinstatement of Taxes for Exporters (REINTEGRA).
  • In part two of International Tax Review’s exclusive interview, Steven Ouwerkerk, global head of tax & treasury at APM Terminals, based in the Netherlands, discusses the transition from adviser to in-house professional, analyses the challenges an in-house tax team faces, and stresses the importance of thinking divergently to find creative solutions.
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $54.8 billion Shire plc AbbVie Inc. Davis Polk & Wardwell - Michael Mollerus Acquisition $8.5 billion Dollar Tree Inc. Family Dollar Stores Inc. Davis Polk & Wardwell Acquisition $3.5 billion Zillow Inc. Trulia Inc. Davis Polk & Wardwell Acquisition $1.68 billion BTG Pactual Banca della Svizzera Italiana (BSI) Skadden - James Anderson, Alex Jupp, Melanie Shaw, Thomas Kim Acquisition $297 million Dürr AG HOMAG Hengeler Mueller Acquisition $175 million LinkedIn Corporation Bizo Inc. Fenwick & West - Adam Halpern, William Skinner Acquisition $170 million Aalberts Industries Impreglon SE Hengeler Mueller Acquisition $100 million ServiceNow Inc. Neebula Systems Ltd. Fenwick & West - Adam Halpern, Will Skinner, Gilad Yacubovich Acquisition Undisclosed Autodesk, Inc. Shotgun Software Inc. WSGR Fenwick & West - Adam Halpern, Idan Netser, Zach Jones, Arnold Keizer Acquisition Undisclosed Yahoo RayV Fenwick & West - Idan Netser Meitar Liquornik Geva Leshem Tal Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Bridge Facility $5.7 billion Tyson Foods, Inc. Morgan Stanley Senior Funding, Inc. Davis Polk & Wardwell Weil, Gotshal & Manges Senior Notes Offering $3 billion Morgan Stanley Morgan Stanley & Co. LLC Davis Polk & Wardwell - Lucy Farr, Andrew Smith Sidley Austin Term Loan Facility $2.5 billion Tyson Foods, Inc. Morgan Stanley Senior Funding, Inc. Davis Polk & Wardwell Weil, Gotshal & Manges Initial Public Offering $1.77 billion NN Group N.V. Deutsche Bank AG, London Branch, ING Bank N.V., J.P. Morgan Securities plc, Morgan Stanley & Co. International plc Allen & Overy Davis Polk & Wardwell - John Paton, Alon Gurfinkel, Rhiannon Nakano Notes Offering $1.25 billion Toyota Motor Credit Corporation Barclays Capital Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated and RBC Capital Markets, LLC Davis Polk & Wardwell - Lucy Farr, Rachel Kleinberg, Koonho Cho Notes Offering $1 billion CSX Corporation Citigroup Global Markets Inc., Credit Suisse Securities (USA) LLC, Morgan Stanley & Co. LLC and UBS Securities LLC Davis Polk & Wardwell - Harry Ballan, Adam Bedzow Shearman & Sterling Bonds Offering $1 billion Greenland Global Investment Ltd BOCI Asia Limited, The Hongkong and Shanghai Banking Corporation Limited, J.P. Morgan Securities plc and Deutsche Bank AG Davis Polk & Wardwell - Alon Gurfinkel, Maer Harel, Lena Qiu Linklaters Senior Secured Credit Facilities $1 billion Rovi Corporation Morgan Stanley Senior Funding, Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated, Fifth Third Bank and SunTrust Robinson Humphrey, Inc. Cooley Davis Polk & Wardwell - Craig Phillips, Neetin Gulati Revolving Credit Facility $1 billion Estée Lauder Companies Inc. JPMorgan Chase Bank Davis Polk & Wardwell - Po Sit Senior Notes Offering $750 million Moody's Corporation J.P. Morgan Securities LLC and Merrill Lynch, Pierce, Fenner & Smith Inc Gibson, Dunn & Crutcher Davis Polk & Wardwell - Michael Mollerus Senior Notes Offering $404 million China Unicom (Hong Kong) Ltd. China Limited, Bank of China (Hong Kong) Limited, Industrial and Commercial Bank of China (Asia) Limited, DBS Bank Ltd., China International Capital Corporation Hong Kong Securities Limited, J.P. Morgan Securities (Asia Pacific) Limited and Nomura International plc Freshfields Bruckhaus Deringer Davis Polk & Wardwell Senior PIK Toggle Notes Offering $400 million MHGE Credit Suisse Securities (USA) LLC, Morgan Stanley & Co. LLC, BMO Capital Markets Corp., Jefferies LLC, Nomura Securities International, Inc., UBS Securities LLC and Apollo Global Securities LLC Paul, Weiss, Rifkind, Wharton & Garrison Davis Polk & Wardwell - Harry Ballan, Tracy Matlock Offering of Common Shares $193.9 million Kosmos Energy Ltd Barclays Capital Inc. Simpson Thacher & Barlett, Conyers Dill & Pearman Ltd Davis Polk & Wardwell - Michael Mollerus, Ameya Bapat Credit Enhanced Convertible Bonds Offering $161 million China Yongda DBS Bank Ltd., UBS AG Linklaters Davis Polk & Wardwell - Alon Gurfinkel, Sarah Joy Senior Notes Offering and Capped Call Transactions $130 million The KEYW Holding Corporation RBC Capital Markets, LLC and Merrill Lynch, Pierce, Fenner & Smith Inc Alston & Bird, Holland & Knight Davis Polk & Wardwell - Po Sit, Lucy Farr, Aaron Weil
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