Foreign Affiliates

News & Analysis as of

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

BE-10 Report: The Overlooked International Reporting Form -The June 30 Deadline is Fast Approaching

The Bureau of Economic Analysis (“BEA”), an agency of the U.S. Department of Commerce, is currently conducting a benchmark BE-10 survey that requires the filing of a BE-10 report by any U.S. person that directly or indirectly...more

Internal Investigations: The Three C’s – Confidence. Credibility. Cost.

In this issue: - THE THREE C’S — CONFIDENCE, CREDIBILITY AND COST - WHO CONDUCTS THE INVESTIGATION? - SCOPE OF THE INVESTIGATION - MINDSET AT THE OUTSET OF AN INVESTIGATION - THE NEED FOR...more

In Case You Missed It - Interesting Items for Corporate Counsel - June 2015

The SEC’s Division of Economic and Risk Analysis issued analysis on the “potential effect on pay ratio disclosure of exclusion of different percentages of employees at a range of thresholds.” Without even trying to follow the...more

Important June deadline for ALL owners of at least 10% of a foreign enterprise

As you may be aware, May 29, 2015 was the deadline for certain filings on Form BE-10 required by the U.S Bureau of Economic Analysis. The filings must be made by any U.S. person that had a “foreign affiliate” in 2014, which...more

Dealing with Rejection: Options for Applicants Not Selected in the FY2016 H-1B Lottery

The U.S. Citizenship and Immigration Services (USCIS)’s announcement last month that it received nearly 233,000 H-1B petitions for fiscal year 2016 beginning October 1, 2015—a record total, and a 35% increase over last...more

New Requirement to File BE-10: Benchmark Survey of U.S. Direct Investment Abroad

Any U.S. person with a foreign affiliate is required to file the 2014 Form BE-10, Benchmark Survey of U.S. Direct Investment Abroad by June 30, 2015 or face civil penalties between $2,500 and $25,000. Further, a willful...more

Form BE-10 Filing Deadline Extended

As reported in last week’s edition of Corporate & Financial Weekly Digest and our client advisory, each US person who had a “foreign affiliate” at any time during its 2014 fiscal year is required to file a Form BE-10 report....more

Impending Deadline for Bureau of Economic Analysis Surveys May Cause Unprepared U.S. Companies to Be Subject to Penalties

Every five years, the U.S. Bureau of Economic Analysis of the U.S. Department of Commerce (BEA) conducts a “benchmark” survey regarding U.S. direct investment abroad by country and industry. The purpose of the survey is to...more

Form BE-10 Filing Deadline Looms

Every five years, the Bureau of Economic Analysis of the US Department of Commerce (BEA) conducts a survey concerning the extent of investment abroad by US individuals and entities (US persons). In the past, only US persons...more

BEA Filing Deadline Looms For US Persons With Foreign Affiliates

Every five years, the US Department of Commerce's Bureau of Economic Analysis (BEA) conducts a survey concerning the extent of investment abroad by US individuals and entities (US persons). In the past, only US persons...more

Mutual Funds with CFCs: Take Note of BE-10 Reporting Requirements

Mutual funds with Controlled Foreign Corporations may need to file a BE-10 with the Bureau of Economic Analysis or request an extension before the reporting deadline....more

Reporting Requirement for All U.S. Persons That Hold Interests in Foreign Affiliates

Pursuant to the requirements of the International Investment and Trade and Services Survey Act and related statutes, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) collects information on international...more

May 29th Filing Requirement for U.S. Companies with Foreign Affiliates

U.S. Companies with foreign subsidiaries and other affiliates are required to report to the U.S. Department of Commerce Bureau of Economic Analysis (BEA) by May 29 or June 30, 2015, depending on the number of foreign...more

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