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  • The limits to the use of the Central Bank reserves are being intensely discussed in Argentina.
  • New Basel rules are affecting everyone differently. In the UK banks are worried about grandfathering, in Germany the headache is hybrids and in the US it's risk structures. Meanwhile Japan has some tips and Hong Kong structured its first hybrid
  • By Roddy Martin and Gary Lock Herbert Smith
  • By Jens Hörmann P+P Pöllath & Partners
  • By Geert Potjewijd and Rogier van Bijnen De Brauw Blackstone Westbroek N.V.
  • By Gilberto Ayres Moreira and Aude Lovigny Rolim Godoi Viotti & Leite Campos
  • By Takuya Eguchi and Takeshi Komatsu Mori Hamada & Matsumoto
  • As we have previously discussed in this column, in September 2008 the US Senate Permanent Subcommittee on Investigations released a report entitled Dividend Tax Abuse: How Offshore Entities Dodge Taxes on US Stock Dividends. The report describes a range of transactions allegedly employed by financial institutions aimed at enabling non-US clients to avoid US withholding taxes on dividends paid with respect to US equities. Such dividends, if paid to a non-US person, are generally subject to a 30% US withholding tax since they are US sourced. As described in the report, US withholding taxes on dividends are allegedly avoided through the use of, among other financial arrangements, equity swaps.
  • Historically, restructurings performed before Romanian courts have been inefficient due to lengthy and complicated court procedures. Only 1.5% of restructurings performed through the court are completed successfully. The rest end in bankruptcy.
  • In December 2009, the Tokyo Stock Exchange (TSE) announced an amendment to its rules regarding stock acquisition rights (SARs) abolishing the requirement under the Implementation Rules for the TSE Listing Standard that one share must be issued when a listed stock acquisition right is exercised. This amendment, which effectuates a part of the Listing System Improvement Action Plan 2009 published by the TSE, is intended to promote the use of rights issues as an alternative to public offerings of shares.