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George Clarke, Kevin Kenworthy and Elizabeth McGee address the uncertainty surrounding the application of the work-product doctrine for tax practitioners.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $417 million Cals Refineries Ltd Cenco and Atas Oil Refinery (Hardt Group) Shearman & Sterling - Bernie Pistillo, Amy Lewis Acquisition Undisclosed Cinven SLV Group Hengeler Mueller - Matthias Scheifele Acquisition Undisclosed Warburg Pincus Beijing Fanhua Datong Investment Management Co. (CNinsure Inc) Davis Polk & Wardwell - John Paton, Alon Gurfinkel Latham & Watkins Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Acquisition financing $3.6 billion PPL Capital Funding Inc BofA; Merrill Lynch, Pierce, Fenner & Smith; Credit Suisse Securities Davis Polk & Wardwell - Rachael Kleinberg SEC-registered offering $1 billion Limited Brands Inc Merrill Lynch, Pierce, Fenner & Smith; JP Morgan Securities; Citigroup Global Markets Davis Polk & Wardwell - Neil Barr, Arie Rubenstein Cahill Gordon & Reindell SEC-registered offering $1 billion Cliffs Natural Resources Citigroup; JP Morgan; Merrill Lynch, Pierce, Fenner & Smith Davis Polk & Wardwell - Harry Ballan, Andrew Teruo Hayashi Initial Public Offering $137.3 million ServiceSource International Morgan Stanley & Co Inc; Deutsche Bank Securities Inc Wilson Sonsini Goodrich & Rosati Davis Polk & Wardwell - Rachael Kleinberg, Ryan LaRosa Equity offering $50 million Affymax Inc Lazard Capital Markets; Stifel Nicolaus Weisel Cooley Davis Polk & Wardwell - Rachael Kleinberg, Ryan LaRosa

Protesters on both sides of the debate over the Australian government’s carbon tax proposals have taken to the streets this week. Marches in favour of and against the plans have been held in Sydney and Brisbane, with both sides of the debate seemingly having support in numbers.

With more economic activity comes more pressure on tax directors to be certain that the processes, systems and structures they have in place will help them achieve tax-efficient outcomes.

Companies may get an incentive to look at the UK more favourably when making investment decisions if reports in the media are to be believed.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.9 billion Solvay Rhodia Freshfields, Bruckhaus & Deringer; Gide Loyrette Nouel - Laurent Modave; Loyens & Loeff - Christophe Laurent Bredin Prat - Julien Gayral, Jean-Florent Mandelbaum Merger $2.35 billion Diamond Foods Pringles (Procter & Gamble) Fenwick & West - Michael Solomon, Will Skinner Acquisition $500 million Safran SNPE Matériaux Energétiques Gide Loyrette Nouel - Guillaume Jolly, Marina Rodrigues Bredin Prat - Pierre-Henri Durand, Magali Buchert Acquisition $169 million Watts Water Technologies Danfoss Socla Bredin Prat - Julien Gayral Acquisition $60.75 million Swiss Liberty Sdn Bhd (TA Global Bhd) Swissôtel Kunshan (Kingdom Hotel Investments) Blake Dawson Hogan Lovells - Philip Gershuny Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Acquisition financing $2.05 billion Diamond Foods Bank of America; Merrill Lynch, Pierce, Fenner & Smith Fenwick & West Davis Polk & Wardwell - Avishai Shachar, Michael Bretholz Secondary offering $1.2 billion Repsol YPF Credit Suisse; Deutsche Bank; Goldman Sachs; Itau BBA; Morgan Stanley; Raymond James; Santander Investment Davis Polk & Wardwell - Mary Conway, Rachel Kleinberg, Rhiannon Nakano Simpson Thacher & Bartlett SEC-registered secondary offering $1 billion NXP Semiconductors NV Credit Suisse Securities; Goldman Sachs & Co; Morgan Stanley & Co Simpson Thacher & Bartlett Davis Polk & Wardwell - John Paton, Adam Perry SEC-registered offering $450 million Verisk Analytics Merrill Lynch, Pierce, Fenner & Smith; JP Morgan Securities Davis Polk & Wardwell - Harry Ballan, Juelle Gomes Skadden, Arps, Slate, Meagher & Flom Term loan credit facility $325 million Western Refining Bank of America Davis Polk & Wardwell - Catherine Paskoff Chang, Juelle Gomes Shearman & Sterling

If taxpayers are to take advantage of new emerging economies they must play an integral role in the development of the countries’ tax systems, leading tax officials and directors have told an international conference.

The head of tax at the OECD has urged taxpayers that tax needs to be top of their company’s agenda amid growing calls for greater tax transparency.

Application of Article 56 EC and Article 40 EEA. Proceedings between the European Commission and the Porutguese Republic concerning the latter's failure to fulfil its obligations in accordance with the aforementioned articles of EU law because it conferred an undue advantage to public debt securities issued by the Portuguese State. If funds were invested in public debt securities issued not by the Portuguese State, a higher rate was applicable. The Court ruled this was a discriminatory practice.

The European Court of Justice (ECJ) has found that Portugal failed to fulfil its obligations under Article 56 EC and Article 40 of the European Economic Area (EEA) Agreement. The judgment was made based on Portugal’s preferential tax treatment of investment in public debt securities issued by the Portuguese state, which conferred an undue advantage.