TAX LAW WEBINAR: Section 1031 Exchanges
Nowotny on Private Placement Group Variable Deferred Annuity Contracts for Tax Exempt and Foreign Investors
Nowotny on Private Placement Variable Deferred Annuities
Nowotny on Private Placement Life Insurance
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
FCPA Compliance and Ethics Report-Episode 154-Compliance Leadership-Persuasion, Influence, Tools & Tips, Skills and Tips
Tax Provisions in Business Acquisition Agreements
Fund and Adviser Tax Issues
State and Local Taxation: Headline News and Trends (January 2015)
How the Rise in Undercover Investigations is Changing the Law
State and Local Taxation: Headline News and Trends (CPE/CLE)
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Hodgson Russ's Tim Noonon on the Groundbreaking New York Residency Tax Case Gaied v. NYS Tax Appeals Tribunal
How to Avoid Corruption Risks in China
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
Polsinelli Podcasts - The Explosion of Tax Credits in 2014
Cross-Border Update on Investing and Doing Business in the United States
Tax Developments Affecting Health Care Organizations and Investor-Owned Hospital Companies
Did the IRS Just Help or Hurt the Bitcoin Economy?
IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN.
What happens when settling parties agree that the defendant will...more
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
I. Overview -
On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more
Two more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program. Yesterday, DOJ announced that bank zweiplus ag (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato)...more
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more
A reader recently sent in the following questions:
Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...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 July 13, 2015, President Putin signed the Federal Law On the Free Port of Vladivostok, as well as two other laws introducing revisions to the current laws required to implement the Law On the Free Port of Vladivostok - the...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
Offshore e-commerce service providers should make themselves aware of changes to Japanese law that affect their operations.
Pursuant to a recent amendment of the Consumption Tax Act, a new Registration of Foreign...more
Beginning with foreign bank account reports (FinCEN Form 114, known as the FBAR) for the 2016 calendar year, FBARs will be due on April 15 of the following year. A six-month extension to October 15 will be available upon...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 INDONESIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT?
The existing Indonesian Investment Act is Law No. 25 of 2007, passed by the Indonesian House of Representatives...more
Bring up the topic of FBARs (Report of Foreign Bank and Financial Accounts) with someone who has foreign financial accounts and the conversation will most likely take a nosedive. With an enforcement regime which can apply...more
Last week Congress passed, and the President signed, a bill entitled “The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.” While this legislation was primarily directed at extending federal...more
Falling Oil Prices Are Not the Only Deterrent to Investment in Mexico's Oil Fields -
On July 15, Mexico auctioned 14 shallow-water exploration blocks. The auction marked the first time in nearly eight decades that...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
On August 11, 2015, the Organisation for Economic Co-operation and Development (OECD) released its annual report addressing global tax administration. The OECD’s stated mission is to “promote policies that will improve the...more
On July 24, the World Trade Organization (WTO) announced that 54 WTO members had reached a tentative agreement to expand the scope of the Information Technology Agreement (ITA) by adding 201 products, including new-generation...more
The Justice Department continues to announce resolutions with banks under its previously-announced Swiss Bank Program. On August 6, DOJ announced the names of three more Swiss banks receiving non-prosecution agreements:...more
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