Foreign Corporations

News & Analysis as of

UK Autumn Statement 2016

This was Chancellor Phillip Hammond's first (and last) Autumn Statement. From Autumn 2017, there will be an Autumn Budget for the coming year, which will enable greater scrutiny of complex tax provisions, followed by a Spring...more

First Enforcement of a QIC Judgment in the State of Qatar

In a landmark case (Protech) last week, a judgment of the Qatar International Court ("QIC") has been successfully enforced by the courts of the State of Qatar....more

Development of Russian court practice on tax implications when dividends are paid to foreign companies (application of the...

On 13 October 2016 the Commercial Court of Kemerovo Region delivered a judgement in case No. ?27-20527/2015 (the “Decision”) under the claim of Krasnobrodsky Yuzhny Limited Liability Company (the “Company”)....more

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Decision to Block LinkedIn in Russia Demonstrates Russian Government’s Commitment to Enforce New “Localization” Requirements for...

- Recent amendments to Russia’s data processing rules require that databases used to process personal information of Russian citizens be located in the Russian Federation, even if the data is maintained by foreign...more

Incorporating In Delaware May Not Eliminate Director Liability Under This California Statute

Some readers may have skipped this week’s posts discussing director liability under California Corporations Code Section 316 on the theory that the statute applies only to directors of corporations incorporated under the...more

New Delaware Chapter 15 Filing – Abengoa Concessions Investments Limited

Anders Christian Digemose, the foreign representative of Abengoa Concessions Investments Limited (“ACIL”) in a proceeding under Part I of the United Kingdom’s Insolvency Act of 1986, has filed a petition for recognition of a...more

Brexit: What’s Ahead? Let the Games Begin

This is the fourth in an ongoing series of Dashboard Insights blog posts on the implications of the June 23, 2016 voter referendum in the United Kingdom (“UK”) to exit the European Union (“EU”) (“Brexit”). Prior articles...more

FCPA Enforcement Going Forward in the Trump Administration

Donald Trump has gone on the record as saying the Foreign Corrupt Practices Act (FCPA) is a “horrible law and it should be changed” and that it puts US businesses at a “huge disadvantage.” This statement was made in the...more

New Regulations Issued Regarding CFCs and Investment in U.S. Property

Income earned abroad by U.S. controlled foreign corporations can often qualify for deferral of U.S. income tax. If the foreign corporation is a controlled foreign corporation (CFC), its U.S. shareholders may be taxable on...more

Follow the money - the Criminal Finances Bill

The Criminal Finances Bill sets out measures to combat money laundering and tax evasion that will also affect corporate compliance requirements, particularly in the finance and professional services sectors....more

Another Step to Speed Up the Company Registration Process in China

Under the current company registration procedures of the People’s Republic of China, before undertaking the approval and/or registration procedures for establishing a company, the investor(s) of a new company must first file...more

What Law Governs Real Property Conveyances By Foreign Corporations?

Consider the following fact pattern - Joe is the Chief Executive Officer of Transient, Inc., a Delaware corporation that is headquartered in Dallas, Texas. Transient’s sole asset is 100 acres of undeveloped land in...more

Impact of New Tax Regulations on Intercompany Debt Obligations

The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more

New Delaware Chapter 15 Filing – Catalyst Paper Corporation

Catalyst Paper Corporation and thirteen of its affiliates and subsidiaries filed petitions for relief this morning under Chapter 15 of the Bankruptcy Code (Case No. 16-12419). The Debtors are seeking recognition of a foreign...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

An Introduction to Corporate Guarantee

In the UAE, the risk management activities inherent in running a corporate or investment banking business remain of crucial importance, not least because of the strong local characteristic of “name lending”, by which is meant...more

Using corporate structures to own UK residential property – a dead end?

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

Why Set up a Local Company in the UAE?

Dubai is a well-respected pathway to the East, and since it became a financial hub, companies that engage in all types of business activities are now looking to establish a presence here. Setting up a Local Company is an...more

Alert: New US Debt-Equity Rules Target Earnings Stripping

On October 13, 2016, the IRS and the Treasury Department issued new rules largely designed to prevent highly related corporate taxpayers from claiming the tax benefits of “earnings stripping,” or the payment of excessive...more

Final and Temporary Debt-Equity Regulations Under Section 385 Implement Highly Favorable Changes

On Oct. 13, 2016, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final and temporary regulations under Section 385 governing the treatment of certain instruments as debt or equity...more

UAE Freezones: Ras Al Khaimah

Ras Al Khaimah Free Trade Zone (RAK FTZ) is a free zone based in RAK and was established in 2001. The free zone has over 5,000 companies as its members cover various fields and economic activities....more

Doing Business in the Kingdom of Saudi Arabia

As the third largest recipient of foreign direct investment in the region, not to mention its standing as the region’s largest economy, the Kingdom of Saudi Arabia is of significant interest to foreign investors, particularly...more

Business Laws and Regulations in Dubai, UAE

With its stellar growth, Dubai has been known for alluring every business opportunists due its efficient licensing rules, infrastructure, and ease of work. In a survey "the World Bank's Ease of Doing Business Survey for...more

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

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