Hot Topics in International Trade USMCA facilitation
AGG Talks: Cross-Border Business Podcast - Episode 18: Navigating U.S. Sanctions and Their Implications for Non-U.S. Individuals and Entities
AGG Talks: Cross-Border Business Podcast - Episode 16: The Political and Legal Maze of ESG in the U.S. and Abroad
Hot Topics in International Trade-Braumiller Law Group-FDI Into Mexico from China
AGG Talks: Cross-Border Business Podcast - Episode 14: Resolving Cross-Border Conflicts Through International Arbitration
Legal Challenges Part 1 – Setting Up Your Startup for Success
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
AGG Talks: Cross-Border Business - Episode 12: A General Counsel’s Map for International Business Expansion - Part 2
AGG Talks: Cross-Border Business - Episode 12: A General Counsel’s Map for International Business Expansion - Part 1
Hot Topics in International Trade-De Minimis With Bob Brewer, and Robert Stein, VP Braumiller Consulting
Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review
AGG Talks: Cross-Border Business - How Foreign Companies Can Protect Their IP and Brand in the U.S.
Hot Topics in International Trade- The Importer of Record
Hot Topics in International Trade-Reasonable Care
Hot Topics in International Trade-Foreign Trade Zone (FTZ) Benefits
AGG Talks: Cross-Border Business - Privacy & Cybersecurity Considerations for Non-U.S. Companies
AGG Talks: Cross-Border Business — Episode 7: Trans-Pacific Business: Australia and the U.S. - Part 2
AGG Talks: Cross-Border Business — Episode 7: Trans-Pacific Business: Australia and the U.S. - Part 1
Hot Topics in International Trade
The Now and Next in International Trade: 5 Fast Facts About CFIUS – a National Security Agency You Should Know
On July 17, the U.S. Treasury and IRS released final regulations targeting various inbound cross-border transactions broadly referred to as “Killer B” transactions, marking the end (for now) of a long-running regulatory fight...more
The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more
Our Doing Business in Québec guide provides an overview of the legal framework governing Canadian business operations in the province of Québec. This guide provides up-to-date information about the following topics: •...more
The global wave of the two-pillar solution to address base erosion and profit shifting, commonly known as BEPS 2.0, has formally washed ashore in Singapore. It is now certain that multinational enterprises (MNEs) with local...more
Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more
On Thursday, November 4, 2021, the Office of the Superintendent of Financial Institutions announced that, subject to approval by the superintendent, Canadian banks and other financial institutions may begin repurchasing their...more
The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more
The 2021 Canadian Federal Budget, released on April 19, 2021, proposes new rules that would fundamentally alter the interest deductibility landscape for Canadian businesses. The thrust of the new rules (referred to herein as...more
Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances of the device requirement for spinoffs and signaled a willingness to relax...more
UK COVID-19 Developments - HMRC updates its trading activities guidance - HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more
Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more
In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more
Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
What kinds of cloud computing transactions take place in your jurisdiction? As a G7 economy with mature IT and related services markets, the UK is one of the most important global markets for cloud computing. According to...more
The Organization for Economic Cooperation and Development (OECD) released a draft proposal today detailing how countries should approach the taxation of multinational companies in an increasingly digitalized global economy....more
On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more
On July 2, 2019, the Bureau of Economic Analysis released the 2018 numbers for foreign direct investment (FDI) in the US. Total 2018 FDI was $273 billion and of that figure, European investors accounted for $116 billion or...more
Considerable thought and commentary has been given to the numerous technical features introduced by P.L. 115-97 (Dec. 22, 2017), colloquially referred to as the “Tax Cuts and Jobs Act” (the “TCJA”). Nearly one-and-a half...more
The 2019 Canadian federal budget was released on March 19, 2019 (Budget Day). As many of the proposals are aimed at investing in Canada’s middle class, the Budget was relatively light on proposals affecting businesses....more
• Public consultation follows release of OECD discussion draft on potential tax changes to address difficulties in taxation caused by the digital economy. • OECD hopes to produce “consensus document” with proposed...more
Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more
OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more
The US M&A market delivered another year of strong performance in 2018. Though deal volume dipped 2 percent year-on-year to 5,682 deals, deal value was up by 15 percent over the period, to US$1.5 trillion - A number of...more
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan with respect to base erosion...more