FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs
FCPA Compliance and Ethics Report-Episode 171-FCPA Enforcement in the Energy Industry
Meritas Capability Webinar - Controlling Where to Fight and Who Pays for it?
FCPA Compliance and Ethics Report-Episode 170-Yas Froemel and Facilitation Payments
FCPA Compliance and Ethics Report-Episode 169-the First Mailbag Issue
CorpCast Episode 6: A Brief Introduction to the Delaware Rapid Arbitration Act
FCPA Compliance and Ethics Report-Episode 168-Dan Cogdell on criminal procedure issues in defending an individual prosecuted criminally under the FCPA
FCPA Compliance and Ethics Report-Episode 167-Mara Senn on the Top 10 Practices in a Cross-Border Investigation
FCPA Compliance and Ethics Report-Episode 166-Sepp Blatter Resigns
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
FCPA Compliance and Ethics Report-Episode 163-the FIFA Indictments, with Mike Brown
FCPA Compliance and Ethics Report-Episode 162-Kristine Robidoux on new Canadian whistleblower initiatives
FCPA Compliance and Ethics Report-Episode 161-Gini Dietrich on how to create a MasterClass
FCPA Compliance and Ethics Report-Episode 160-Compliance Week 2015 Wrap Up with Mike Volkov and Jay Rosen
FCPA Compliance and Ethics Report-Episode 159-Alison Taylor on the intersection of CSR and the FCPA
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Meritas Capability Webinar - California’s Prohibition Against Non-Compete Agreements (B&P Code § 16600), the Protection of Trade Secrets and the Practical Relationship Between the Two
Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
FCPA Compliance and Ethics Report-Episode 154-Compliance Leadership-Persuasion, Influence, Tools & Tips, Skills and Tips
FCPA Compliance and Ethics Report-Episode 153-Doing Compliance in an Economic Downturn
The Cayman Islands has long been the most prominent offshore jurisdiction through which to structure offshore private equity and venture capital funds.
Why the Cayman Islands?
The attractions for international...more
The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more
Four years after enacting the largest tax increase in Connecticut history, the Connecticut General Assembly has adopted a new $40.3 billion biennial state budget that contains $1.5 billion in tax and fee increases.
Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look at the most recent developments in Massachusetts corporate tax, provide some administrative updates, and discuss some hot...more
After much promise, the IRS issued two sets of regulations to address the potential avoidance of gain by corporate partners. First, new § 337(d) temporary regulations, often referred to as the “May Company” regulations,...more
When a business owner is working on selling his or her business, there is a lot of planning that goes into the process. One important aspect of selling a business is to work out a tax strategy. In any business sale, potential...more
On May 18, 2015, the U.S. Supreme Court decided Comptroller of the Treasury of Maryland v. Wynne, No. 13-485, holding that the absence of a credit against the local portion of the state’s personal income tax scheme was an...more
The IRS proposed regulations [REG-132634-14] to provide guidance on what is “qualified income” from a publicly traded partnership’s (PTP) activities regarding minerals or natural resources, such as oil and gas fracturing...more
In Mac’s Convenience Stores Inc. v. Canada (2015 QCCA 837), the Quebec Court of Appeal affirmed a lower court decision (2012 QCCS 2745) denying rectification of corporate resolutions that had declared a dividend that...more
It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their...more
In a statement that would mark a stark change in approach, an IRS official recently indicated that the IRS may begin requiring that companies seeking to effect tax-free spinoffs conduct active businesses that represent a...more
The IRS announced earlier this week that it may temporarily stop reviewing private letter ruling requests on the issue of whether a spin-off qualifies as tax-free under Section 355. More specifically, the IRS may hit pause on...more
The OECD has released a Discussion Draft on Cost Contribution Arrangements (CCAs) as part of its ongoing activities related to eliminating Base Erosion and Profit Shifting (BEPS) by multinational enterprises.
The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of...more
On July 29, 2014, the State Administration of Taxation (SAT) of the People’s Republic of China (PRC or China) released The Notice Regarding the Launch of Tax Anti-Avoidance Investigations on Remittance of Substantial Amounts...more
A buyer who orders a tax due diligence review before acquiring a company wants to get information not only about the tax risks that may exist for that company, but also about its existing tax assets (both those assets that...more
Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more
Allied Domecq Spirits & Wines USA, Inc. v. Comm’r of Revenue, 85 Mass. App. Ct. 1125 (2014) -
In a unique case, the Massachusetts Appeals Court affirmed a ruling of the Appellate Tax Board (ATB) that two corporations...more
“In terrorem” or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in 1997, is no exception, so that even now certain fundamental questions relating...more
A recent Memorandum issued by the Office of Chief Counsel within the Internal Revenue Service demonstrates yet again the perils of failing to comply with Section 409A of the Internal Revenue Code. The Memorandum takes the...more
On May 5, 2015, the Internal Revenue Service (IRS) issued two long-awaited rulings, Rev. Rul. 2015-09 and Rev. Rul. 2015-10, that should ease the lives of corporate tax planners. Each ruling addressed an increasingly common...more
By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques.
A pair of revenue rulings the US Internal Revenue Service (IRS)...more
We have recently received a positive ruling from U.S. Customs and Border Protection (“Customs”) in response to a protest filed on behalf of one of our clients which is a U.S. subsidiary of a European parent company and...more
Business aircraft operations are highly regulated by several government agencies. Structuring the ownership and operation of business aircraft in compliance with this regulatory environment is difficult and requires...more
Proposed regulations seek to provide rules for determining MLP qualifying income from certain activities and services performed with respect to minerals or natural resources.
On May 5, 2015, the Internal Revenue...more
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