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Earlier this year the IRS issued a technical advice memorandum (TAM 200807015) disallowing foreign tax credits claimed by a US bank in a structured foreign tax credit transaction. A TAM is guidance provided by the Office of Chief Counsel upon request of an IRS director. It represents a final determination of the position of the IRS with respect to the specific issue on which the TAM is issued. Generally, a request for a TAM stems from an examination of a taxpayer's return or a consideration of a taxpayer's claim for a refund or credit. This TAM marks the first concrete evidence that the IRS is coming good on its promise to attack structured foreign tax credit transactions when it finds them.

Record Indian equity offering The State Bank of India's dramatic headquarters Amarchand & Mangaldas & Suresh A Shroff & Co and J Sagar Associates have advised on a $4.38 billion rights issue for the State Bank of India (SBI) – the second-largest Indian equity offering to date. Amarchand Mangaldas, working alongside Allen & Overy's Hong Kong office, advised SBI on the offering, which included a $2.5 billion subscription by the Indian government. J Sagar Associates, along with Clifford Chance Hong Kong, advised the managers on the fully-subscribed issue.

Italy's minority shareholder rights have been clarified. This may lead to more disputes though

While broadly agreeing with bankers' counsel, James Tanenbaum believes that some are overly optimistic on Sarbanes-Oxley and too critical of the ratings agencies

The Financial Services Authority has named its new chairman.

The New York Stock Exchange's announcement that it will list Special Purpose Acquisition Companies could lure investors back to the US and legitimise the investment entity

The release of the US Financial Accounting Standard Board's new standard last week has lawyers embracing the idea of more disclosure and transparency among bond insurers

The buy-side didn't want it. The sell-side didn't want it. And the legal community wasn't keen. But ignoring opposition to ratings reform, Moody's has introduced new measures to ward off the threat of external regulation

Sébastien Vilder has joined Blakes Cassels & Graydon's Montreal office as partner in the financial services group.

The burgeoning trend of Special Purpose Acquisition Companies (Spacs) has finally hit Asia, with China's first high-profile case