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  • The double taxation avoidance treaty (DTA) between Hong Kong and the Netherlands, signed last year, will enter into force in 2012 and will increase the tax planning opportunities for companies in both jurisdictions.
  • The Authority for Advance Rulings (AAR) in the case of Columbia Sportswear Company [2011-TII-21-ARA-INTL], adjudicated on the taxability of procurement activity undertaken by a non-resident company through its liaison office (LO) in India.
  • A single European market in the area of taxation still does not exist. In practice, this means that multinational corporations doing business in the EU need to navigate their way through (up to) 27 different national tax administrations and administrative requirements, and widely differing national interpretations of EU tax law, directives and regulations.
  • The Finnish Central Tax Board (CTB) has given a preliminary ruling (KVL 34/2011) regarding taxation in connection with transfers of investments in life insurance saving agreement and capitalisation agreement where the taxpayer has the right to decide on which assets the policy funds are invested in.
  • Type of Agreement Country Country Date Signed Double taxation avoidance agreement UAE Kenya November 21 2011
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $11 billion Gilead Sciences Pharmasset Inc Skadden, Arps, Slate, Meagher & Flom Sullivan & Cromwell - Ronald Creamer Merger $860 million ACCO Brands Corporation MeadWestvaco Corporation's Consumer & Office Products Business Skadden, Arps, Slate, Meagher & Flom - Maxwell Miller; Barclays Capital Acquisition Undisclosed Madsack Frankfurter Allgemeine Zeitung (Markische Allgemeine) Hengeler Mueller - Ernst-Thomas Kraft Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Registered public offering $700 million Canadian National Railway Company Davis Polk & Wardwell - Samuel Dimon, Changsheng Song; Stikeman Elliott Sullivan & Cromwell Term loan facility $500 million NXP BV Barclays Capital; Credit Suisse Securities Simpson Thacher & Bartlett Davis Polk & Wardwell - Michael Mollerus Senior notes offering $260 million KKR Financial Holdings Citigroup Global Markets; Morgan Stanley; UBS Securities; Wells Fargo Securities Simpson Thacher & Bartlett Davis Polk & Wardwell - Po Sit, Arie Rubenstein SEC-registered notes offering $250 million Rockwell Collins Inc Merrill Lynch, Pierce, Fenner & Smith; Citigroup Global Markets; Wells Fargo Securities Davis Polk & Wardwell - Michael Mollerus, Jason Chlipala Revolving credit facility $200 million El Paso Electric Company Union Bank; JP Morgan Securities Davis Polk & Wardwell Hughes Hubbard and Reed; Cravath Swaine & Moore Initial public offering $114 million Angie's List Inc Merrill Lynch, Pierce, Fenner & Smith; Allen & Co; Stifel; Nicolaus & Co; RBC Davis Polk & Wardwell - Rachel Kleinberg, Una Au Common stock offering $62.3 million Kennedy-Wilson Holdings Inc Merrill Lynch, Pierce, Fenner & Smith; Deutsche Bank Securities Latham & Watkins; Kulik, Gottesman, Mouton & Seigel Davis Polk & Wardwell - Michael Farber, Kay Ng Restructuring Undisclosed Sbarro Inc Cantor Fitzgerald Securities Kirkland & Ellis; Rothschild Davis Polk & Wardwell - Samuel Dimon, Neil Barr, Kay Ng, Rhiannon Nakano, Anthony Oliva
  • The issue of a general anti-avoidance rule (GAAR) in the UK has been long-discussed. Now that Graham Aaronson QC has submitted his final report on the feasibility of a UK GAAR to the government, here are 10 things you cannot afford to miss.
  • The UK government has decided to end VAT relief available on products from the Channel Islands, effective from April 1 2012, saying it will bring increased fairness for UK businesses, benefit the economy and protect millions of pounds in tax revenue.
  • The issue of a general anti-avoidance rule (GAAR) in the UK has been long-discussed. Now that Graham Aaronson QC has submitted his final report on the feasibility of a UK GAAR to the government, here are 10 things you cannot afford to miss.
  • Following House Ways & Means Committee chairman Dave Camp’s (Rep-MI) release of a discussion draft proposal to reform the US corporate tax regime in late October, several hearings have taken place which suggest US tax reform in the near future is inevitable.
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