Monday, April 29, 2013

Analysis: Tax strategy may be key to Verizon Wireless deal

By Kevin Drawbaugh and Nanette Byrnes

(Reuters) - Verizon Communications Inc's chances of buying the 45-percent stake in Verizon Wireless owned by the UK's Vodafone Group Plc will hinge, at least in part, on the quality of tax advice it is getting.

Verizon, the No. 2 U.S. telecommunications company, may have found a way to structure a purchase of the stake so that Vodafone can avoid a multi-billion dollar U.S. capital gains tax bill, sources familiar with Verizon's plans said. The possibility of a huge tax bill has previously been regarded by analysts as a big hurdle to any such deal.

Reuters reported last Wednesday that Verizon was preparing a bid worth about $100 billion to take full control of Verizon Wireless - it already owns the other 55 percent - by buying the stake, according to people familiar with the matter. There are no guarantees that Vodafone will want to sell its stake or that Verizon will pursue the plan.

Vodafone declined to comment on the possibility of a Verizon bid for its stake or on the tax question.

One person familiar with the situation said Vodafone cannot consider the size of any tax payout in a possible transaction until the company has received an offer, which it has not.

A Verizon spokesman declined to comment.

Verizon hopes that if it structures a transaction to eliminate much of the tax bill, it can encourage Vodafone to come to the table for talks. Some analysts and investors say Verizon may have to pay as much as $130 billion to clinch the deal.

The tax bill on $100-billion deal, based on a simple acquisition of the stake, would be about $38 billion, according to UBS Investment Research. It could be much higher if the deal's price-tag rises above that figure, UBS noted.

That tax bill is based on the massive growth Verizon Wireless has experienced since it was established 13 years ago. The 45-percent stake that Verizon Communications wants to buy is owned by Vodafone Americas, a U.S. holding company. Given it is a U.S. entity, if Vodafone Americas were to sell that stake outright it would have to pay the full capital gains tax on the stake.

But the sources said Verizon Communications is contemplating a two-part deal that could avoid this. Instead of buying the stake outright, the sources said, Verizon Communications would buy the Delaware-based Vodafone Americas. Analysts said the seller of Vodafone Americas would not be a U.S.-based entity, so no U.S. capital gains tax would be due.

Vodafone's international structure is complicated, involving many holding companies, and the precise ownership of some assets is unclear. Vodafone Americas also owns some of Vodafone's non-US assets, the sources said, probably including some in Germany and Spain. These would be sold back to Vodafone by Verizon Communications, which would keep the Verizon Wireless stake, they said.

The two transactions could be done simultaneously or one after the other.

While the sale of the Verizon Wireless stake would not incur capital gains tax, the sale of the international assets back to Vodafone would. This is because it would involve the sale of assets by Verizon Communications, a U.S. entity.

Compared to Verizon Wireless, the smaller international assets are thought to have gained little in value. Analysts estimated their sale could hit Verizon Communications with a U.S. tax bill of about $5 billion or less.

The sources said that Verizon would seek to pass any tax hit onto Vodafone in the two-part transaction.

LONG COURTSHIP

Verizon has long coveted its partner Vodafone's stake in the Verizon Wireless joint venture, which started operations in 2000.

The last time the two came close to a deal was in 2004, when Vodafone bid for AT&T Wireless. The British company, the world's second-largest mobile operator, however, lost that bid to Cingular and has since held on to the Verizon Wireless stake for its exposure to the U.S. wireless market.

Wall Street analysts had previously seen it as unlikely that Verizon would want to do a deal involving Vodafone Americas' international assets. But those assets have underperformed in recent years when compared with the growth of Verizon Wireless, and are now a smaller part of the holding company, reducing the potential tax hit.

However, the timing of Verizon's interest in doing the deal has more to do with the gains in its stock price and low interest rates, the sources stressed.

Verizon is considering paying about half of the purchase price in cash and half in stock, Reuters reported on Wednesday. That means it may look to raise around $50 billion in debt.

UK TAX QUESTION

The kind of deal structure envisaged would still leave Vodafone with another tax question, said UK academics and analysts: Should it leave the proceeds from any sale offshore or bring them home to the UK?

Leaving the money offshore might invite scrutiny from the U.S. Internal Revenue Service, which sometimes questions transactions if they seem designed solely to avoid tax and are not based in an underlying economic logic, said Prems Sikka, professor of accounting at the University of Essex in the UK.

If the transaction were shaped the way the sources have described it, Vodafone would probably repatriate the proceeds into Britain, said Charles Merriman, managing director at Merriman Capital Transactions, a consultancy in London.

Once that was done, he said, the company might be able to reduce its tax bill by taking advantage of the UK's substantial shareholdings exemption. Under certain conditions, this exempts from UK corporation taxation any gains realized when one company disposes of shares in another company.

More broadly, though, Vodafone could face a political backlash in the UK from any deal that was clearly structured to avoid taxation, said Robin Bienenstock, senior analyst at Bernstein Research.

U.S. companies such as Starbucks, Amazon and Google have come under fire from British lawmakers for using legal maneuvers to cut their tax bills in the UK.

"The problem with tax is not just the technical ability to avoid it, but the scorched earth that trying to avoid it could leave with the UK government afterwards," said Bienenstock. "Recent tax cases in the UK ... suggest that an attempt to avoid tax on such a large and high profile deal would be very badly received."

(Reporting by Kevin Drawbaugh in Washington, D.C. and Nanette Byrnes in Chapel Hill, N.C.; Additional reporting by Kate Holton and Tom Bergin in London; So Young Kim and Paritosh Bansal in New York; Editing by Martin Howell)

Source: http://news.yahoo.com/analysis-tax-strategy-may-key-verizon-wireless-deal-050341644.html

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Lawyers, public chant "hang him" as Bangladesh building owner led to court

By Ruma Paul and Serajul Quadir

DHAKA (Reuters) - Bangladeshi lawyers and protesters chanted "hang him, hang him" on Monday as the owner of a factory building that collapsed last week killing nearly 400 people was led into court dressed in a helmet and bullet-proof jacket, witnesses said.

The drama came as rescue officials said they were unlikely to find more survivors in the rubble of the building that collapsed on Wednesday, burying hundreds of garment workers in the country's worst industrial accident.

Heavy cranes were being used to lift huge concrete blocks from the wreckage of Rana Plaza, where 385 people are now confirmed to have been killed. The building housed factories making clothes for Western brands.

Eight people have been arrested - four factory bosses, two engineers, building owner Mohammed Sohel Rana and his father, Abdul Khalek. Police are looking for a fifth factory boss, David Mayor, who they said was a Spanish citizen.

Rana, a local leader of the ruling Awami League's youth front, was shown on television being brought to Dhaka in handcuffs after he was seized in the border town of Benapole by the elite Rapid Action Battalion following a four-day manhunt.

Rana was arrested by police commandos on Sunday, apparently trying to flee to India.

"Put the killer on the gallows, he is not worth of any mercy or lenient penalty," one onlooker outside the court shouted.

The court ordered that Rana be held for 15 days "on remand" for interrogation.

Khalek, who officials said was named in documents as a legal owner of the building, was arrested in Dhaka on Monday. Those being held face charges of faulty construction and causing unlawful death.

Bangladesh does carry out the death penalty for murder and for most serious categories of manslaughter.

Hundreds of the mostly female workers who are thought to have been inside the building when it caved in remain unaccounted for. A fire overnight further hampered the last desperate efforts to find survivors.

"We are giving the highest priority to saving people, but there is little hope of finding anyone alive," army spokesman Shahinul Islam told reporters at the site.

About 2,500 people have been rescued from the wrecked building in the commercial suburb of Savar, about 30 km (20 miles) from the capital, Dhaka.

Late on Sunday, sparks from rescuers' cutting equipment started a fire in the debris as they raced to save a woman who may have been the last survivor in the rubble. Her body was recovered on Monday afternoon.

"We could not save her, even though we heard her voice this morning," a tearful rescue worker told reporters at the scene.

Officials said the eight-storey complex had been built on swampy ground without the correct permits, and more than 3,000 workers - most of them young women - entered the building on Wednesday morning despite warnings that it was structurally unsafe.

A bank and shops in the same building closed after a jolt was felt and cracks were noticed on some pillars on Tuesday.

The collapse was the third major industrial incident in five months in Bangladesh, the second-largest exporter of garments in the world behind China. In November, a fire at the Tazreen Fashion factory in a suburb of Dhaka killed 112 people.

Such incidents have raised serious questions about worker safety and low wages in the poor South Asian country, which relies on garments for 80 percent of its exports. The industry employs about 3.6 million people, most of them women, some of whom earn as little as $38 a month.

In a development that may raise questions about the authorities' handling of the rescue operation, a spokesman at the British High Commission on Monday confirmed that an offer of technical assistance from Britain had been declined.

Anger over the disaster has sparked days of protests and clashes, and paramilitary troops were deployed in the industrial hub of Gazipur as garment workers took to the streets again on Monday, smashing cars and setting fire to an ambulance.

The unrest forced authorities to shut down many factories, which had reopened on Monday after two days of closures. Police fired teargas to disperse protesters.

The main opposition has called for a national strike on May 2 in protest over the incident.

Emdadul Islam, chief engineer of the state-run Capital Development Authority, said last week that Rana had not received the proper construction consent for the building, and had illegally added three stories to the original five.

(Writing by Alex Richardson and Nick Macfie)

Source: http://news.yahoo.com/little-hope-more-survivors-bangladesh-toll-nears-400-080033210.html

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Friday, April 26, 2013

Facebook to acquire Parse, promises easier cloud-based app development

Facebook to acquire Parse, promises easier cloudbased app development

Hot on the heels of its Mobile Developer Conference, Facebook today announced its intentions to buy cloud-based app development service Parse, a company with which the site has collaborated in the past. According to a post on Facebook's Developers blog, the purchase will go a ways toward helping devs, "rapidly build apps that span mobile platforms and devices." The acquisition will bring a number of cloud-based tools like data storage, user management and notifications to Facebook developers. For each company's take on the news, check out the source links below. We also spoke to a Facebook spokesperson, who told us, "This is an acquisition, not a talent deal." As for financial terms, they wouldn't say.

Comments

Source: Facebook, Parse

Source: http://www.engadget.com/2013/04/25/facebook-parse/?utm_medium=feed&utm_source=Feed_Classic&utm_campaign=Engadget

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Syria says backing rebels risks new attacks on America

By Michael Stott and Samia Nakhoul

DAMASCUS (Reuters) - U.S. support for Syrian rebels may lead to more attacks on American soil like those of September 11, said a senior Syrian official who warned that Islamist fighters would spread "the fire of terrorism" around the world.

Western powers are alarmed at al Qaeda militants joining a revolt that began two years ago with rallies for democracy and President Bashar al-Assad has seized on that unease; now, 10 days after the Boston Marathon bombings, Syria's deputy foreign minister told Reuters that U.S. aid to the rebels may backfire.

"Once the fire of terrorism spreads in Syria it will go everywhere in the world," Faisal Mekdad said in an interview.

Referring to foreign jihadists whose presence has made the United States and European allies wary of arming Syrian rebels, he said: "These chickens will go back to roost where they came from because encouraging terrorism definitely backfires ... Once these terrorists succeed in Syria, they will go everywhere."

Speaking in fluent English at the heavily guarded white, stone-clad complex in central Damascus which houses the Foreign Ministry and prime minister's offices, Mekdad drew a comparison, made also by Assad himself, with the U.S.-backed Muslim holy war against Soviet occupiers in Afghanistan that fostered al Qaeda.

And asked whether the Boston bombings, blamed on radicalized Muslim immigrants, might change American views of a Syrian conflict that Assad has long painted as a war on terrorism, he replied: "I hope the American administration will remember again the September 11 attack - which we strongly condemned in Syria - and not repeat these policies which encourage terrorism."

Of 37 nationalities of "terrorist" he said were fighting in Syria, many were European, Mekdad said, including some from Russia's Chechnya region, ancestral home of the Boston suspects.

Assad's critics have argued that he himself is paying a price for helping Islamists from Syria and elsewhere - letting them cross into Iraq to fight U.S. forces there; some of those seasoned fighters have now joined the campaign to overthrow him.

Like other senior officials interviewed lately in Damascus, Mekdad projected a breezy confidence in Syrian forces' ability to win the civil war and denied the rebels were gaining ground.

While condemning support for the mainly Sunni Muslim rebels from Sunni neighbors such as Saudi Arabia, Qatar and Turkey, as well as the Western powers, he said his government enjoyed broad international support, not limited to Russia or to Iran, whose Shi'ite branch of Islam is close to Assad's Alawite minority.

"I would like to say, with all confidence, that all Syria is controlled by the government but there are places where armed groups have been armed, financed, by certain circles - namely Qatar, Saudi Arabia, France and the UK and other European countries - who due to logistical reasons may control this or that part of Syria," he said. "But this is moving every day."

A man living near the Foreign Ministry, who did not want to be identified, told Reuters the complex had been attacked four times in recent months, twice with mortars and twice by men firing machineguns: "We are very frightened," he said, recalling how he took cover during the last mortar attack 10 days ago.

Asked when the government might win, Mekdad said it was combating "terrorist groups and usually in all those countries which have suffered the plague of terrorism it takes time".

"Once this support from neighboring and European countries ceases we can easily deal with it," said Mekdad, who hails from Deraa where protests began in March 2011 after teenagers were jailed for pro-democracy graffiti inspired by the Arab Spring.

He cited apparent success in offensives in Homs and near the western border, where rebels say Lebanese Hezbollah fighters are supporting Syrian troops. Going was also slow, he said, due to "the care practiced by the government with civilians".

The United Nations has said more than 70,000 people, have been killed and many countries have condemned shelling and aerial bombing by Syrian forces of residential areas.

CHEMICAL "LIE"

Mekdad dismissed Western and Israeli claims that government forces had used chemical weapons, saying it was a "big lie" that Syria was blocking a U.N. investigation into the allegations.

He said Damascus had an initial agreement with the U.N. to look into claims that chemical weapons were used in the Khan al-Assal area near Aleppo but matters were complicated when the U.N. wanted to broaden the probe to include other allegations:

"We are ready to receive immediately the team to investigate the case of Aleppo, to provide all the logistics, help and support and protection and it is the responsibility of the U.N. secretariat if this delegation doesn't arrive in Syria."

A former Syrian ambassador to the United Nations, Mekdad accused Britain and France of trying to complicate the U.N. investigation to prevent evidence emerging of rebel use of chemical shells, but did not offer evidence for the allegation.

The United Nations wants inspectors to investigate claims of chemical weapons use in Homs in December; France and Britain say the mission should look into a third alleged case in Damascus.

President Barack Obama has warned Assad that deploying chemical weapons would cross a "red line" that could prompt the United States to intervene in unspecified ways in the conflict - so far, however, Washington has said firm evidence is lacking.

Mekdad denied that Damascus was receiving arms and military support from Russia or fighters from Iran or Hezbollah, Tehran's Lebanese Shi'ite ally; foreign supporters were providing only humanitarian aid and Syria had ample reserves of its own.

"We are not isolated, we don't feel isolated," he said of efforts to impose international sanctions. "Besides Russia, we have China, India, South Africa and we have almost all Latin American countries, and Africa and other Asian countries."

He warned the EU against helping rebels sell oil from captured fields in the north: "That is a direct theft of Syrian property," he said. "We are still a government and a strong government. We will stop them," he added without elaborating.

Mekdad reflected the government's contention that Syria has been targeted by U.S.-allied Sunni Arab powers because it was part of "an axis of resistance", along with Iran and Hezbollah, and accused Sunni-led states of secretly supporting Israel: "We believe the main objective in attacking Syria is to weaken it as a major power and to implement Israel's policies in the region in connivance with the United States and Western interests."

Asked how he believed the conflict would end, Mekdad sketched two scenarios: "Either we opt for a political solution as projected by President Assad in his speech on January 6 ... or the other scenario where the main objective of arming, harboring and smuggling armed groups into Syria will continue."

"In this case, we have a strong army, we have a strong country, we have determination by the majority of Syrians to combat terrorism. But our preference and the preference of the Syrian leadership is to work for a political settlement."

Assad offered in that speech in January to negotiate with the opposition if they laid down their arms but he refused dialogue with "gangs recruited abroad" and his foes dismissed the offer out of hand as it did not mention Assad stepping down.

(Editing by Alastair Macdonald)

Source: http://news.yahoo.com/syria-says-backing-rebels-risks-attacks-america-162137596.html

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BBC plans 'Tweet of the Day,' radio for birds

LONDON (AP) ? Remember when tweeting was for the birds?

The BBC is hoping to revive that simpler time with "Tweet of the Day" ? an early-morning radio program dedicated to British birdsong.

Veteran naturalist David Attenborough will host the 90-second show, which will feature the song of a different bird each weekday, along with background on the species' behavior and habits.

The show on the BBC's main speech station, Radio 4, may be best appreciated by those who rise with the birds. "Tweet of the Day" will be broadcast at 5:58 a.m.

The BBC said Wednesday that 265 different birds will be featured during the year-long series, which begins next month with a recording of the cuckoo. Attenborough will host for the first month, and be followed by other BBC presenters.

Source: http://news.yahoo.com/bbc-plans-tweet-day-radio-birds-112446764.html

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Thursday, April 25, 2013

Former government lawyer charged with espionage

By Lawrence Hurley

WASHINGTON (Reuters) - U.S. prosecutors on Thursday alleged that a former federal government lawyer helped the Cuban intelligence service recruit a woman who was later sentenced to 25 years in prison for spying.

An indictment filed in 2004 was unsealed in the U.S. District Court for the District of Columbia charging Marta Rita Velazquez with conspiracy to commit espionage for her alleged role in recruiting Ana Belen Montes to the Cuban intelligence service and helping her get a federal government job.

Velazquez and Montes became friends while studying together at the Johns Hopkins University School of Advanced International Studies in Washington, D.C. in the early 1980s, according to the indictment.

In 1984, Velazquez took Montes to New York, where they met with a Cuban intelligence officer, the government alleged. Velazquez, who the Justice Department said kept in contact with Cuba via encrypted messages, also traveled with Montes to Cuba in 1985, according to the indictment.

Velazquez now lives in Sweden and is unlikely to ever face trial, a federal law enforcement official said. During her government career, Velazquez worked as a lawyer at the U.S. Agency for International Development, where she had top secret security clearance.

Montes, who worked at the U.S. Defense Intelligence Agency for 16 years, was arrested in 2001 and later pleaded guilty to an espionage offense. She is still serving her prison sentence.

The indictment against Velazquez was originally filed in 2004 but kept sealed until Thursday.

Velazquez, who is from Puerto Rico, left the United States in 2002 after news of Montes's guilty plea, according to the Justice Department.

A Justice Department official said Velazquez was aware of the charge and that there was no longer any reason to keep the indictment sealed. The extradition treaty between the United States and Sweden does not allow for extraditions for espionage, the official added.

(Reporting by Lawrence Hurley; Editing by Howard Goller and Cynthia Osterman)

Source: http://news.yahoo.com/u-announces-espionage-charge-against-former-government-lawyer-211714192.html

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