Front Line Interview Episode 1. Alison Taylor: Organizations, Compliance & Corruption
FCPA Compliance and Ethics Report-Episode 189-Compliance Evangelist
The Social Engineering Cyber Exposure
Taking A Proactive Approach to Cyber Security
An FCPA Journey to the Darkside & Steps to Protect Your Organization
What is a hostile work environment?
CorpCast Episode 8: The Controlling Stockholder
From Behind the Bribe: The Sharp End of Compliance
Strong Market Outlook Drives Growth of Philippine Companies
Why do we have to go to mediation?
FCPA Compliance and Ethics Report-Episode 178-Ben Locwin on Risk Assessments
Do I need an expert witness in my case?
Marketing to Millennials
CorpCast Episode 7: Better Know a Judge: the Honorable Mary M. Johnston of the Delaware Superior Court
Top Three Cybersecurity Misconceptions
Preparing a Company to Deal With Activist Investors
How can someone prepare for the first meeting with an attorney?
CorpCast Episode 6: A Brief Introduction to the Delaware Rapid Arbitration Act
The Intersection of Cyber and D&O Coverage
Talking PTAB with Bob Steinberg
On 4 August 2015, the governments of Cyprus and Iran signed an agreement for the avoidance of double taxation (the Treaty). With the lifting of international sanctions against Iran, Cyprus is now uniquely positioned to act as...more
WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more
WHAT ROLE WILL THE GOVERNMENT OF JAPAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
Generally speaking, foreigners can conduct business in Japan on an equal legal footing with Japanese citizens. The...more
HM Treasury has published a consultation paper setting out proposed reforms to UK limited partnerships law with a focus on private fund structures (the “Consultation Paper”). The consultation includes a draft legislative...more
On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more
Thank you for your interest in the 5th Annual IRS Hot Topic Seminar held in Jerusalem in July. In continuing our efforts to provide timely and extremely important updates on tax matters affecting U.S. citizens and green card...more
On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"), which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more
1. WHAT ROLE WILL THE GOVERNMENT OF INDIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
Historically, India has been a regulated economy since its independence. The government of India (GOI) launched a new...more
On August 6, 2015, the Treasury and the IRS issued Notice 2015-54, which implements a Clinton-era tax provision intended to prevent U.S. taxpayers from using the partnership provisions of the Code to shift built-in gain on...more
Supreme Court rules in favour of taxpayer in landmark case regarding UK tax treatment of Delaware LLCs.
On 1 July 2015, the UK Supreme Court handed down a long-awaited ruling in the case of Anson v Commissioners for Her...more
The Kingdom of Thailand is a sovereign country
(514,000 sq. km) located in South-East Asia bordered by
Burma in the north and west; Laos to the north and east;
Cambodia to the east; and Malaysia to the south. It has...more
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
Hong Kong is always rated as one of the world’s freest economies, one of the reasons being that the government has always adopted the approach of nonintervention.
Hong Kong strives to attract more foreign investors to...more
In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more
1. WHAT ROLE WILL THE GOVERNMENT OF CHINA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
In the past, foreign investment in China was highly regulated. However, following China’s entry into WTO in 2001,...more
On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect...more
This outline discusses, in plain English, the regulatory provisions called into play under IRC § 367(b) on acquisitive mergers and other non-divisive corporate reorganizations. A Section 367(b) acquisitive reorganization...more
The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015.
The Draft Bill contains significant changes to the German tax...more
What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…).
In June 2014, the European Court of Justice (ECJ) ruled that the...more
On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more
The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more
The French 3 Percent Distribution Tax: Claiming a Refund -
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
The number of additional months of funding for transportation projects under a $8 billion bill introduced late last night in the House. Notably — as anyone on Sesame Street could tell you — the number 5 is not the same as the...more
The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place...more
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