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The first global bond offering from one of Korea Electric Power Corporation's (Kepco's) generation subsidiaries has set a useful precedent for the market, showing how to avoid triggering a default on bonds should the issuer be privatized in future.

For the first time a UK company is relying on US bankruptcy proceedings to protect it from US creditors while remaining solvent elsewhere.

What was to be the first ever New York listing of a Chinese private enterprise has been shelved, in part because of added regulatory burdens imposed by the Sarbanes-Oxley Act.

The Bond Market Association (TBMA) last month released a proposal draft of a new version of its Cross-Product Master Agreement (CPMA). The Agreement is an industry standard intended to harmonize agreements among agents conducting transactions in the swaps, repo, securities lending and currency markets. The revised draft takes the first version of the CPMA and expands its scope with the aim of reducing risk and instability in those markets.

In the past, Hungarian offshore companies (HOCs) registered in, and performing activities outside, Hungary paid a beneficial 3% corporate profits tax. Companies that requested HOC status before December 31 2002 may benefit from the 3% tax rate and the related HOC regulations during a transitional or grandfathering period, which expires on December 31 2005. However, no company can request HOC status after January 1 2003.

Douglas Bartner, Michael Bosco, James Garrity and Stacey Spevak of Shearman & Sterling explain how Grapes became the first foreign company with minimal assets in the US to achieve restructuring under Chapter 11

In a recent case, a company domiciled and taxable in France owned the entire share capital of a company domiciled in Geneva. The Swiss subsidiary was solely set up to hold and administer securities and as such benefited from the so-called holding company privilege, a favourable tax status accorded by both the Federal and Cantonal tax laws. However, under the French Tax Code, section 209B (Controlled Foreign Company Rules or CFC rules), a French company's share in the income of a company domiciled abroad, in which the former holds a participation either of 10% or more or with a value of at least €22.8 million ($24.3 million), is added, for tax purposes, to its domestic (French) income, provided that the foreign company enjoys a privileged tax treatment at its domicile.

The understandable haste of Asian governments to create insolvency frameworks to revitalize their post-1997 economies has created as many problems as it has solved. Robert Zafft of the OECD and Lampros Vassiliou of Allens Arthur Robinson explain

The Shoura Council, a highly influential consultative group made up of some of the leading Saudi Arabian nationals, has rejected a proposed 10% income tax on foreign individuals. While, Saudi Arabia levies corporate taxes, it has traditionally not levied an individual income tax on expatriate workers. However, the country was considering levying a tax on expatriates as a means of reducing public debt and reducing the number of foreign workers in the hope that unemployed Saudi Arabian nationals would replace them.

Italy's regions, provinces, municipalities and other local entities can now securitize proceeds derived from the divestment of real estate assets under Law No 289 (December 27 2002). These territorial entities have become equal, in this respect, to the central government, which can finalize this kind of transaction under Law Decree No 351 (September 25 2001) as converted with amendments into Law No 419 (November 23 2001). For more details see IFLR, International briefings, January 2002.