Brazilian American Law Center - Provisional Waiver for Unlawful Presence
Brazilian American Law Center - Upclose and Personal
Marketing to Millennials
CorpCast Episode 7: Better Know a Judge: the Honorable Mary M. Johnston of the Delaware Superior Court
Brazilian American Law Center - Estao Chegando Os Alquemistas
Brazilian American Law Center - Falando Serio
CorpCast Episode 6: A Brief Introduction to the Delaware Rapid Arbitration Act
Introducing the Brazilian American LawCenter
If I won my case, why do I need to worry about an appeal?
CorpCast Episode 4: Better Know a Judge: Vice Chancellor J. Travis Laster of the Delaware Court of Chancery
Will 2015 Bring New Regulations for Bitcoin Users?
Schoenbrod: SCOTUS Ruling Helps EPA Deal With a "Stupid Statute"
New Video Series with the ACC Provides Peer-To-Peer Ethics & Compliance Training for Senior Executives
Did the IRS Just Help or Hurt the Bitcoin Economy?
SOX Whistleblower Protections Extend to Private Companies: Critical Steps to Take Now
Law Prof: The Clean Air Act Needs a Reboot
Lease Negotiations – Interview with Jeff Moerdler, Member, Mintz Levin
Structuring Compensation Programs – Interview with David Lagasse, Member, Mintz Levin
Executive Compensation Packages – Interview with David Lagasse, Member, Mintz Levin
Earn-Out Arrangements – Interview with David Lagasse, Member, Mintz Levin
The Stunning Altera Case -
Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more
On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more
BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more
The European Commission's recent state aid crusade against so-called sweet deals in the form of tax rulings may have unwelcome consequences never contemplated by the Commission....more
EU Passes New Council Directive to Implement “EU-FATCA" -
The Council Directive passed by the EU on 1 December 2014 implements the OECD’s Common Reporting Standard (CRS) in Europe. The Directive has to be implemented...more
On January 20, 2015, the Canada Border Services Agency (CBSA) issued revisions to its Administrative Monetary Penalty System (AMPS), found in Memorandum D22-1-1 Administrative Monetary Penalty System....more
On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations aimed at blunting certain of the benefits from so-called inversion...more
Until recently, the Luxemburg Government had resisted the European Commission's attempts to disclose the beneficiaries of tax rulings. It had even taken the information injunction to the EU Court of Justice. This has now...more
On 5 November 2014, a group of investigative journalists ("ICLG") placed approximately 540 rulings granted by the Luxembourg tax administration to some 340 companies active in a large number of industries (energy, financing,...more
On 10 April 2014, the European Court of Justice ("ECJ") issued a judgment in case C-190/12 concerning the authority of Poland to grant corporate income tax ("CIT") exemption to investment funds depending on where their...more
The European Court of Human Rights takes a stand on the ne bis in idem principle intervening on the relationship between administrative and criminal violations involving identical facts. Two recent decisions give interesting...more
In a recent decision, the New York State Division of Tax Appeals soundly rejected a determination by the New York State Department of Taxation and Finance (the "Department") that it could treat a banking corporation’s...more
The Plight of Billionaires Looking For New
Havens to Shield Assets
by James F. McDonough, Jr. on July 30, 2013
In a recent article in Wealth Management, the author David de Jong and Robert Lafranco describe the...more
Italian Law No. 228 dated December 24, 2012, which approved the 2013 budget, contemplates, among others, a new tax applicable to certain financial transactions (the “Tobin Tax”).
The Tobin Tax will apply to transactions,...more
This is the eleventh year in which the CRA has issued such a report, which is generally intended to enhance taxpayer awareness of the APA program and to describe (i) current operational status, (ii) relevant changes, and...more
Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more
On December 26, FinCEN issued Notice 2012-2 to extend the deadline for certain filers to submit the Report of Foreign Bank and Financial Accounts (FBAR). FinCEN has extended this deadline several times in the past and the...more
Recently proposed changes in UK law could affect private investment funds that operate or have partners, employees or investments in the UK. Many of the proposed changes are included in the draft Finance Bill 2013, which was...more
Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts.
For those U.S. taxpayers who are married to non-residents there is a new form of marriage penalty if the spouses filed joint returns. To be eligible to file joint returns an election must be made with the first joint return...more
On December 31, 2012, the Consumer Financial Protection Bureau (“Bureau”) published in the Federal Register revisions (“Proposal”) to rules on international remittance transfers that the agency published in February 2012 and...more
This update summarises current regulatory developments impacting the
asset management sector in the UK and throughout the European Union.
In this issue:
- Part A – Regulation of Financial Markets
- Part B –...more
Tax lawyer Stuart Schabes co-presented “FATCA – 2013 and Beyond” at The Perfect Storm: US Tax Legislation and IRS Compliance 2013, a program hosted by Philip Stein & Associates and ERM.
Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more
In This Issue:
* EU CUSTOMS POLICY
- MCC/UCC recast proposal
- Update on duty suspensions/tariff quotas
- EU preferences adopted for Pakistan
- FTA update
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