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  • 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 $175 million LinkedIn Corporation Bizo Inc. Fenwick & West - Adam Halpern, William Skinner 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 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 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 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 Intial Shares Offering $130 million Alexander Forbes Group Holdings Ltd Deutsche Bank AG, London Branch, Morgan Stanley & Co. International plc and Rand Merchant Bank Bowman Gilfillan Inc., Davis Polk & Wardwell - John Paton, Omer Harel Freshfields Bruckhaus Deringer, Edward Nathan Nathan Sonnenbergs Inc.
  • Adam Kobos, an energy tax specialist, has joined Troutman Sanders office in Portland, Oregon as a partner. He was formerly with Stoel Rives.
  • Ulf Andresen, Jobst Wilmanns and Oliver von Schweinitz of PwC look at the tax and transfer pricing implications of a separation of investment banking from commercial banking.
  • Stefan Ditsch of PwC gives an overview of recent tax developments and a selection of major law changes, tax court decisions and administrative rulings.
  • Roberto Carlos Rivas, Carolina Alexandres and Gabriel Bernal of PwC look at the changes to transfer pricing legislation which came into force in September last year.
  • Transfer pricing reforms, such as the introduction of safe harbour rules, have not reduced litigation or cut the compliance burden in India. And the government’s approach to the BEPS project could increase reporting requirements, explain Rajendra Nayak and Shweta Pai of EY.
  • Adalberto Valadez and Daniel De la Parra of Chevez, Ruiz, Zamarripa y Cia report on the amendments to the Income Tax Law, VAT Law and the Excise Tax Law.
  • Susann van der Ham and Ina Sprenger of PwC critically discuss the recently issued draft ordinance on income allocation of permanent establishments as a further implementation step of the Authorised OECD Approach (AOA) into German tax law.
  • At a time when the global community is focussed on international taxation issues, including in particular the perceived shifting of income or profits from one jurisdiction to another, Canada continues to address these issues through the evolution of its domestic law, explains Jeffrey Shafer of Blake, Cassels & Graydon.
  • Rakesh Nangia of Nangia & Co look at value shifting in the context of the Shell India controversy.
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