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In this presentation:
- Form of foreign operations
- Foreign tax treatment of the foreign operations
- U.S. tax treatment of the foreign operations
- VAT/GST issues
- Employee and...more
The institution of the trust, a creature of the English Court of Equity, evolved deep in the bosom of the Anglo-American legal tradition. France, a civil jurisdiction, lacks a legal institution that is truly comparable. Her...more
In January, there were some particularly important developments with respect to whistleblower protections in connection with federal grants and contracts, as well as Office of Management and Budget (“OMB”) information on the...more
The IRS recently issued proposed regulations amending the rules applicable to a private foundation’s good faith determination that that a foreign grantee is the foreign equivalent of a public charity or private operating...more
On September 24, 2012, the IRS issued Proposed Regulations §§ 53.4942(a)-3 and 53.4945-5 in order to reduce barriers to international grant-making made by private foundations. Secretary of State Hilary Clinton announced the...more
New rules expand the class of tax practitioners qualified to issue good-faith determinations regarding foreign-grantee equivalency; IRS seeks comments on further amendments to current regulations....more
On April 17, 2012, the Department of the Treasury's Office of Foreign Assets Control (OFAC) released new General License 14-C, which authorizes financial transactions under specified circumstances in support of humanitarian,...more
The FCPA paparazzi has a standard list of anti-corruption risks: government interactions, third-party due diligence, gifts and entertainment, and mergers and acquisitions/joint ventures. Notice that charitable giving is not...more
On April 17, the U.S. Treasury issued new General License No. 14-C, which relaxes sanctions on financial services with respect to certain humanitarian and not-for-profit activities in Burma.
This License allows...more
As reported in our prior blog entry, the Report of Foreign Bank and Financial Accounts, Form TD-F 90-22.1 (“FBAR”) must be filed by a U.S. person that holds a financial interest in, or signature or other authority over, a...more
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