Foreign Affiliates

News & Analysis as of

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

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)

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

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?

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

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...

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

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

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

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

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

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...

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

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”

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

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

New Restrictions on Transferring Appreciated Property to Partnerships With Related Foreign Partners

The IRS issued Notice 2015-54 stating that it plans to issue regulations under Section 721(c) to ensure that U.S. taxpayers do not use partnerships to shift built-in gains to non-U.S. affiliates. In 1997 Congress authorized...more

Cassation instance supports tax authorities in Oriflame case

On June 11, 2015, Moscow District Arbitration Court handed down its ruling in the controversial Oriflame case. In the case, the tax authorities challenged the lawfulness of a Russian organization deducting VAT and expenses...more

Global Connection - June 2015

The latest edition of Global Connection offers insight into a potential money laundering crackdown in the real estate sector, information on the Federal Trade Commission’s approach to data breach investigations and a legal...more

U.S. Companies with Foreign Affiliates: Important Deadline for BEA Filing Approaching

The U.S. Bureau of Economic Analysis (BEA) has extended the deadline for first-time filers of BE-10 forms to June 30, 2015. The BEA is willing to consider reasonable requests for extension, provided that the extension...more

US Bureau of Economic Analysis mandatory filings: US persons that own foreign entities and US persons with foreign ownership

Update: Extended deadline for first-time filers of Form BE-10 - The Bureau of Economic Analysis (BEA) has extended the deadline from May 29, 2015 to June 30, 2015 for US reporters that are required to file the BE-10...more

68 Results
|
View per page
Page: of 3
JD Supra Readers' Choice 2016 Awards

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×