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Tax Talk -- Volume 7, No. 1 -- April 2014

In This Issue: - FATCA Update: IRS Releases New Regulations, New Forms, and New IGAs - No Rule Policy on MLPs - IRS Introduces New Grandfather Rule for Equity-Linked Instruments Under Section 871(m) - Rev....more

IRS Says Bitcoin Isn’t Money

On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent...more

IRS: Bitcoin Not A Currency For Tax Purposes

As expected, the U.S. Internal Revenue Service has provided some guidance on the U.S. tax treatment of Bitcoin. In Notice 2014-21 (March 25, 2014), the IRS stated that Bitcoin is property and not currency for tax...more

Virtual Currencies: International Actions And Regulations

Virtual Currencies: International Actions And Regulations. See Chart for more information....more

Bitcoin - Calls for Regulation - Part Eight

“Virtual currencies”, and bitcoin in particular, continued to attract a lot of attention. The sudden shutdowns of Mt. Gox (Japan), a large bitcoin exchange, and Flexcoin (Canada), a bitcoin bank, led to renewed and...more

SEC Wins Freeze Order Over “Cloud Computing” Pyramid Scheme

The “cloud” is a current focus for investors. There is cloud computing, cloud storage and new firms with cloud services. And the Commission discovered a “cloud” investment program that promised a 100% return in 100 days and...more

Poland: Additional payment services available to operators regulated under the Polish Gambling Act

Changes to the Polish Gambling Act have broadened the array of payment service providers that Polish-licensed operators can use. In October 2013, an amendment to the Polish Gambling Act came into force which changed the...more

Orrick's Derivatives in Review - March 2014

Publication of 2014 ISDA Credit Derivatives Definitions - On February 21, the International Swaps and Derivatives Association, Inc. announced the publication of the 2014 ISDA Credit Derivatives Definitions, which...more

Moving Towards a Global Harmonized Approach to Cross-Border Data Transfers?

Today, data can be transferred around the world instantaneously, making the global marketplace seem almost borderless. As any multinational company knows, however, compliance with each country’s data transfer and privacy laws...more

Red Notice Newsletter - March 2014

This month on the anticorruption front, a New York court orders two former Siemens executives to pay record civil penalties in a bribery case involving the company’s Argentina business; Canada prosecutes former executives...more

Bitcoin - Turbulent Waters - Part Seven

“Virtual currencies”, and bitcoin in particular, continued to attract a lot of attention. The sudden demise of Mt. Gox (Japan), one of the largest bitcoin exchanges, adds to the mystery and mistrust surrounding the virtual...more

On The Horizon - Renewable Energy in Asia: Indonesia

1. What are the driving factors for increasing renewable energy production in Indonesia? Energy is a critical factor needed for the development of economic activity and national defense. - Ensuring domestic...more

The European Technology Index: Technology – An engine for growth?

In 2012, in light of the Euro crisis and uncertainty of a double dip recession, DLA Piper launched the first Tech Index survey. This was to review the perceptions and attitudes of European technology growth in light of market...more

Trends in Legal Terms in Venture Financings in Israel 2013

Background — We have analyzed the terms of venture financings for Israeli and Israeli-related technology companies that reported raising money during 2013. Our survey does not include financing rounds of less than US...more

Bitcoin Exchange Mt. Gox Files for Bankruptcy Protection; May Have Broader Implications for Digital Currency Industry

On February 28, 2014, international Bitcoin exchange Mt. Gox filed for bankruptcy protection in Tokyo, capping what is likely the most tumultuous month yet in the history of the controversial virtual currency. Mt. Gox—the...more

The Boricua Option – The Taxation of Incentive Stock Options (ISOs) as a Puerto Rican Resident - Another Good Reason to Move to La...

Overview - 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

OFAC Expands and Clarifies License for Exports of Personal Communications Items and Services to Iran

The Department of the Treasury, Office of Foreign Assets Control (OFAC), amended the Iran personal communications General License D-1 (GL D-1) on Feb. 7, 2014, expanding, clarifying and superseding the May 2013 General...more

Cyber-Security in Corporate Finance

The ICAEW has partnered with a task force, including the Law Society, the London Stock Exchange, the Takeover Panel and the Confederation of British Industry, to publish a guide on ‘Cyber-Security in Corporate Finance’ for...more

National Cybersecurity Framework Released - Has Your Organization Considered the Implications?

On February 12, 2014, the National Institute of Standards and Technology ("NIST") released the final version of its Framework for Improving Critical Infrastructure Cybersecurity (the "Cybersecurity Framework" or "Framework")...more

Russia Cracks Down On Bitcoin

Both the Central Bank of Russia and the Russian Prosecutor General's Office explained that the rouble is the country's sole official currency and that the production of alternative monetary products, such as Bitcoin and other...more

Outward Bound

As Chinese companies have matured, they’re eagerly looking to the U.S. as a source for technology innovation, talent and market penetration, says Jackie Liu, a partner in Morrison & Foerster’s San Francisco office. Until...more

2014 Global Data Centre Market Report

Our inaugural report highlights the current key trends and themes in the global data centre industry and provides an outlook for the data centre market in 2014. We asked people from across the industry (including data...more

"Antitrust and Competition: Nonmerger Enforcement Activity Heats Up on Both Sides of the Atlantic"

U.S. and European antitrust agencies had similar enforcement priorities last year, a trend we expect to continue in 2014. Nonmerger enforcement will continue to focus on intellectual property, financial services and...more

Bitcoin - Big Bounce Back - Part Six

The nature and prospects of “virtual currencies”, and bitcoin in particular, have been keenly debated. In early December 2013, Chinese government authorities took the first steps towards defining and regulating virtual...more

Bitcoin - Freefall in China - Part Five

The nature and prospects of “virtual currencies”, and bitcoin in particular, have been keenly debated. In early December 2013, Chinese government authorities took the first steps towards defining and regulating virtual...more

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