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  • Disputes between oil and gas producing states, especially Rio de Janeiro and Espírito Santo, and non-producing states are likely to cause revisions to Brazil’s indirect tax regime.
  • Baker & McKenzie will start 2012 with a new head of its US Focus Group in Amsterdam when Eric Westerburgen, who specialises in developing and implementing tax-driven international corporate and business restructurings, as well as transfer pricing and supply chain projects, joins the firm on January 1 from Ernst & Young. His clients are mainly for US-based multinationals with strong operational presence in the Netherlands and the rest of Europe.
  • As the sole EU member state to veto the Euro-plus pact last week, the UK signalled its refusal to accept the economic harmonisation desired by other states and is now likely to face increased pressure to implement a financial transactions tax (FTT), warn advisers.
  • The Foreign Account Tax Compliance Act (FATCA) is a complex piece of new legislation that is set to have a far reaching impact on US companies as well as foreign companies with US assets or clients.
  • The Australian government’s plan to build the country’s reputation as a global financial services centre took a step forward last week when it finalised the country’s investment manager regime (IMR).
  • Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $4.2 billion United Rentals, Inc. RSC Holdings Sullivan & Cromwell - Ronald Creamer Paul, Weiss, Rifkind, Wharton & Garrison & Debevoise & Plimpton Acquisition $1.1 billion Apollo Management, L.P. Taminco Group Holdings S.à.r.l. Latham & Watkins Davis Polk & Cahill Gordon & Reindel Acquisition $995 million Fujifilm Holdings Corporation SonoSite Shearman & Sterling Fenwick & West - Michael Solomon, Jay Cosel Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Initial Public Offering $1.9 billion New China Life Insurance Company Ltd. China International Capital Corp. Hong Kong Securities Ltd, Goldman Sachs Davis Polk - John Paton & Adam Perry Revolving Credit Facility $1.25 billion V.F. Corporation JPMorgan Chase Bank, N.A. Davis Polk - Mary Conway & Michael Bretholz Cravath, Swaine & Moore Secondary Offering $650 million Banco Santander Chile Santander Investment Securities Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated Davis Polk - Michael Mollerus, Leslie Altus & Changsheng (Eric) Song Notes Offering $350 million IDEX Corporation J.P. Morgan Securities, Merrill Lynch, Pierce, Fenner & Smith Inc & Wells Fargo Securities Latham & Watkins Davis Polk - Neil Barr, Arie Rubenstein & Juelle Gomes Catastrophe Bond Placement $337 million SCOR Aon Benfield Securities Inc & Natixis SA Walkers Global (Ireland) & Dewey & LeBoeuf Wickersham and Taft
  • Type of Agreement Country Country Date Signed Double Tax Avoidance Agreement Qatar Portugal December 12 2011 Double Tax Avoidance Agreement Taiwan Switzerland December 13 2011 Double Tax Avoidance Agreement India Australia December 16 2011
  • Canadian taxpayers should expect more uncertainty when it comes to the country’s general anti-avoidance rule (GAAR) despite last week’s Copthorne ruling, warns a leading lawyer.
  • Jay Payne has returned to PwC US, as a tax partner in the firm’s Washington Metro practice. He has spent five years as a partner at BDO USA, based in Phoenix, where he was co-chair of BDO’s gaming, hospitality and leisure industry group.
  • India’s Authority for Advance Rulings has clarified the taxability of payments made to a group parent company towards cost allocation for availing support services.
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