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Nélio Weiss Philippe Jeffrey On December 2 2010, the Brazilian Revenue Service issued Declaratory Act 22/2010 (ADE RFB 22/2010) (the Act), based on a request submitted by the Spanish government. The Act suspended the effects of the inclusion of the Spanish Entidad de Tenencia de Valores Extranjeros (ETVEs) in the privileged tax regimes list.

As India prepares itself to introduce general anti-avoidance rules in April 2012, Mukesh Butani of BMR Advisors (Taxand India) highlights the key issues within the new provisions, compares them to the other jurisdictions, and discovers that India has a long way to go in establishing best practices.

The Center for International Policy (CIP) has issued findings which put Mexico at the forefront of Latin America’s outflows of illicit funds through tax evasion.

Elizabeth Bearese investigates the finer details of Canada’s tax treaty with India and explains how the treaty has become increasingly important as the two country’s seek to develop better investor relations.

Another year of transfer pricing development brings hope, for taxpayers and their advisers, that processes will be streamlined, guidelines will provide clarity and policy reform will allow for better interpretation. A new year allows for contemplation about the direction governments and tax authorities should take. Sophie Ashley reports on the expectations of global and regional advances.

Several countries unilaterally introduced bank levies at the beginning of 2011. The risk of double taxation resulting from the lack of coordination is worrying banks. Salman Shaheen finds out if they have anything to fear.

The Chartered Institute of Taxation (CIOT) and five other tax and accountancy bodies have written to the UK Exchequer Secretary, David Gauke, asking him to reconsider the timing of plans for the compulsory use of a new computer language for submitting company accounts to HM Revenue & Customs (HMRC) from April 1.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $5.7 billion AMB Property Corp ProLogis Wachtell, Lipton, Rosen & Katz - Joshua Holmes, Michael Sabbah Acquisition Undisclosed Acal plc CompoTRON GmbH Noerr Schneider, Geiwitz & Partner - Eberhard Maller-Menz Acquisition Undisclosed Continental Property Investments (CPI) Hotel Palacio de Congresos - Eurohypo & Banesto Uria Menendez - Juan Antonio Fernandez-Velilla, Andreas Espinas, Javier Gravalos Garrigues; Mariman Abogados (Eurohypo); Clifford Chance (Banesto) Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) SEC-registered Offering $6.75 billion Lloyds TSB Merrill Lynch; Pierce, Fenner & Smith Davis Polk & Wardwell - John Paton, Adam Perry Allen & Overy Senior Notes Offering $5.25 billion Morgan Stanley Morgan Stanley & Co. Incorporated Davis Polk & Wardwell - Po Sit, Andrew Smith Sidley Austin Equity Offering $1.7 billion Fifth Third Bancorp J.P. Morgan Chase Bank; Deutsche Bank Securities; Credit Suisse Securities; Goldman, Sachs & Co. Davis Polk & Wardwell - Rachael Kleinberg, Sarah Joy High Yield Bond Offering $685 million Labco SAS Shearman & Sterling - Iain Scoon, Simon Letherman Perpetual Notes Offering $230 million BR Malls International Finance Ltd Davis Polk & Wardwell - John Paton, Michael Farber, Michelle Messer, Nicole Field. Skadden, Arps, Slate, Meagher & Flom

Two cases from the Federal Court of Appeal in Canada have opened the door for greater scrutiny of trust arrangements. This new case law, coupled with an emboldened Canada Revenue Agency, will probably mean more pressure on taxpayers that set up these vehicles to avoid income tax. Erin Kelechava looks at the way these cases will affect tax planning and how they may be illustrative of a broader trend against tax avoidance in Canada.

International Tax Review will present its sixth annual European Tax Awards at the Dorchester Hotel in London on May 18 2011.