News & Analysis as of

Foreign Affiliates

SEC Issues Update for Advisers Relying on the Unibanco No-Action Letters

Recently, the staff (Staff) of the US Securities and Exchange Commission's (SEC) Division of Investment Management issued an information update (the "Information Update") for investment advisers registered under the...more

SEC’s Information Update for Advisers Relying on the Unibanco No-Action Letters

by Ropes & Gray LLP on

Recently, the SEC’s Division of Investment Management published a four-page Information Update for Advisers Relying on the Unibanco No-Action Letters (the “Update”). The stated purpose of the Update is to inform...more

U.S. Antiboycott Compliance: New Federal List Published

by Polsinelli on

Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more

Discovery of Nonparty Foreign Affiliates Must Be Tempered by Proportionality

by Pepper Hamilton LLP on

The court’s opinion affirms the principle that relevance, even in the context of a foreign affiliate, must always be tempered by considerations of proportionality, thereby providing defendants an effective argument when...more

New Sedona Conference Commentary Recommends Restricting the Reach of Document Requests Directed to U.S. Affiliates of Overseas...

Earlier this month, the Sedona Conference issued the final version of its “Commentary on Rule 34 and Rule 45 ‘Possession, Custody, or Control.’” The Commentary recommends adopting the “legal right” test to analyze the...more

New USCIS Policy Decision Broadens Permissible Bases for Visa Transfer of Multinational Managers

by Foley & Lardner LLP on

After four years of internal deliberations, U.S. Citizenship & Immigration Services (USCIS) recently issued a policy memorandum binding all USCIS personnel to follow the reasoning of a 2013 USCIS Administrative Appeals Office...more

BEA Filings: Is another report due this year? (IRB No. 552)

by Bryan Cave on

At this time last year, we issued alerts advising U.S. companies of the approach of a recently imposed deadline to file reports with the Bureau of Economic Analysis (“BEA”), a little known agency within the Department of...more

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

Development of the tax practice of the “beneficial owner” concept

by Dentons on

On March 3, 2016 the Commercial Court of Moscow rendered a decision on case No. ?40-241361/15 (the “Decision”) under the claim of BANK INTEZA joint stock company (the “Russian Company”). The decision contains a number of...more

Mandatory BEA Filings: Have You Complied?

by Jackson Walker on

Is your business owned, directly or indirectly, 10 percent or more by a foreign party? Does your business own, directly or indirectly, 10 percent or more of a foreign party? If so, your business may have the legal...more

US and EU Iran Sanctions Relief: What Non-US Persons Need to Know

by Morgan Lewis on

Even in light of EU and US relaxation of sanctions against Iran after Implementation Day, non-US Persons should evaluate any proposed dealings with Iran to make sure such activities do not violate any new or continuing...more

IRS Announces Intent to Tax Transfers to Partnerships With Foreign Partners

On August 6, 2015, the IRS issued Notice 2015-54, which states that the IRS and Treasury intend to issue regulations under section 721(c) of the Internal Revenue Code to ensure that, when a U.S. person transfers certain...more

Intellectual Property Update: Distributing patent rights between affiliates: guidelines to support enforcement rights around the...

by DLA Piper on

Picture the scenario – your company creates a new affiliate in Ireland to sell and distribute a product. The parent company holds the legal title to the patents associated with the product. Parent grants the Irish affiliate a...more

2015-16 Compliance Developments & Calendar for Private Fund Advisers

Registered investment advisers (RIAs) are required to review their policies and procedures on at least an annual basis. As an aid to the required review and to assist with timely completion of required compliance tasks, below...more

Effects of Schrems Ruling on International Internal Investigations

by Morgan Lewis on

In a recent landmark decision, Maximillian Schrems v. Data Protection Commissioner, Europe’s highest court struck down a US-EU agreement that allowed companies to move personal electronic data between the European Union and...more

Supreme Court Declares Canadian Corporations may be Liable for Acts of Foreign Affiliates

by Bennett Jones LLP on

In a just-released decision, Chevron Corp v Yaiguaje, 2015 SCC 42, the Supreme Court of Canada held that Canadian courts have jurisdiction to decide whether a foreign judgment can be enforced in Ontario against either or both...more

New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

by Goulston & Storrs PC on

Earlier this week the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations...more

Unusual Like-Kind Exchanges

by Alston & Bird on

Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more

FINRA Rule 2040 Goes Into Effect

by Burr & Forman on

On August 24, 2015, FINRA Rule 2040 concerning payments to unregistered persons went into effect. The rule, approved by the SEC in January 2015, is aligned with § 15(a) of the Securities Exchange Act of 1934. Generally, FINRA...more

IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

by Morrison & Foerster LLP on

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

The Free Port Vladivostok Area

by K&L Gates LLP on

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

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

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

Treasury Imposes Toll Charge on Some Transfers of Assets by U.S. Taxpayers to Partnerships with Their Foreign Affiliates

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

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

by Michael Volkov on

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between...more

IRS to Provide New Exception to Partnership Formation Nonrecognition When There Are Foreign Partners

by Charles (Chuck) Rubin on

In Notice 2015-54, the IRS indicates it will be issuing regulations under Code Section 721(c) which will provide that transfers of appreciated property to controlled partnerships that have a related foreign partner will not...more

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