Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
Creating an Integrated Due Diligence System - Screening to Audits
Third Party Due Diligence When is Enough, Enough?
An FCPA Review: A Look Back at 2013 and Trends for 2014
Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM
Internal Investigations: Soup to Nuts (March 13, 2014)
How Can You Better Protect Yourself with the Escalating Trend of FCPA Enforcement?
The Role of a Chief Compliance Officer: Navigating the Compliance Landscape (March 18, 2014)
Keeping Your Due Diligence System Manageable March 31, 2014
Tailoring Your Anti Corruption Program to a Risk Assessment
Managing Your Anti Corruption Policies and Procedures
Recognition of Foreign Judgments in the United States (VIDEO)
FCPA Compliance and Ethics Report-Episode 78-2014 FCPA Wrap Up for the first six months
Designing Cost Effective Risk Assessment Programs May 21, 2014
Managing Your Internal Investigation Program June 3 2014
AML BSA and Sanctions Compliance Part II of II June 24, 2014
AML BSA and Sanctions Compliance I of II June 10 2014
A Conversation with Tim Gardner on Asia Restructirungs
FCPA Compliance and Ethics Report-Episode 76-World Cup Report-Part VI
Monitoring and Auditing Your Anti Corruption Compliance Program
Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more
Following its announcement in November 2013, the Australian Government has released draft legislation to enable foreign pension funds to access concessional withholding tax rates under Australia's Managed Investment Trust...more
In This Issue:
- 70 Countries Agree to Share Bank Information in Tax Evasion Probe
- Financial Industry Pushes Back Against Proposed ERISA Requirements
- Federal Reserve Proposes Tougher Stress Tests for...more
On June 10, 2014, the IRS issued Revenue Ruling 2014-18, which holds that nonqualified stock options, as well as stock-settled stock appreciation rights (SARs), do not constitute nonqualified deferred compensation subject to...more
Section 457A of the Internal Revenue Code (the Code) generally restricts the ability of offshore funds and other entities domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S....more
Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more
HMRC’s policy on reclaiming VAT on investment management and other costs remains under review in the light of two recent decisions from the Court of Justice of the European Union.
The first of these cases, PPG...more
In January 2013, the Internal Revenue Service (IRS) published final regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA is intended to make it more difficult for U.S. taxpayers to conceal assets held in...more
The Turks and Caicos Islands (TCI) lie 575 miles southeast of Miami and 39 miles southeast of The Bahamas. There are eight principal inhabited islands which have an estimated population of 35,000. The legal system is based...more
Multinationals with operations in India should take note of the Delhi High Court’s recently decision in Centrica India Offshore Pvt Ltd., in which it upheld a ruling of the Authority for Advance Rulings that an employee...more
The Irish High Court recently considered the transferability of personal retirement savings accounts (“PRSAs”) to overseas jurisdictions. This decision could have important implications for the Irish pensions industry, which...more
The judgment in ATP PensionService A/S v Skatteministeriet (Case C-464/12) was delivered by the European Court of Justice on 13 March 2014. It was the latest in a line of cases concerning the VAT treatment of costs incurred...more
In this Issue:
- Indian FDI into the United States
- Indian Imports into the United States
- Formation of US Subsidiaries
- Liability of Equity Holders
Chile’s business environment is the result of a policy-driven strategy that has focused on building sound macroeconomic fundamentals and strong institutions, promoting competition and international integration, and creating a...more
With more than 196 million inhabitants and over 8.5 million square kilometers, Brazil is the largest country and economy in Latin America (its GNP in 2011 was roughly USD2.07 trillion). It is a federative republic, consisting...more
Bolivia is a country with amazing natural beauty and a diverse landscape, sheltering a fourth of the world’s greatest biodiversity. Bolivia’s riches also include raw material, industrialized material and of course, tourism....more
On March 14, 2014, the OECD released a discussion draft for public consultation, BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (the Discussion Draft), as action item 6 in the OECD’s...more
Many professional living and working in Silicon Valley over the last twenty years have become very wealthy as a result of their participation in company stock options plans – qualified and non-qualified....more
In this presentation:
Road Map: Top Ten Steps to Successful and Compliant International Operations -
- Identify Goals in the Foreign Market: What’s next?
- Phased Approach: Considerations in entering...more
1. What role does the government of Vietnam play in approving and regulating foreign direct investment?
The Ministry of Planning and Investment (MPI) is the central administrative body that oversees all investment...more
1. What role does the government of Thailand play in approving and regulating foreign direct investment?
The Thai government regulates foreign direct investment by requiring foreign investors to obtain approval from...more
As discussed in a prior post, the U.S. Internal Revenue Service (“IRS”) is currently in the process of finalizing its regulations implementing the Affordable Care Act’s (“ACA”) “Employer Mandate.” The Employer Mandate, which...more
The UK Government has included two important changes to corporation tax relief in the draft Finance Bill 2014, both of which are expected to come into force later this year. The changes allow corporation tax relief to be...more
1. What role does 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
Our colleague Ute Krudewagen has put together a list of some key labor and employment issues to consider if and when you decide to take your US-based emerging company to overseas locations.
So you are ready to...more
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