Foreign Entities

News & Analysis as of

PA Tax Law News - September 2014

In This Issue: - Sales Factor Sourcing of Services & Intangibles - Nonresident Limited Partners Liable for Personal Income Tax - PA Appeal Systems Changes Update - Personal Responsibility for...more

The Next Big Thing for Companies Outside the US: US IPOs Using a Yield-oriented Structure

Ten practical considerations can help companies around the world tap the significant US capital market with IPOs. Investors in the United States continue the search for yield. Over the past several years, over 60...more

Indiana DOR Finds Economic Nexus, Disregards UPS

The Indiana Department of Revenue recently concluded that a company that earned royalty income from licensing trademarks and trade names to two of its Indiana affiliates, and had no physical presence in the state, nonetheless...more

Privacy or Politics? – Russia Seeks More Control Over its Citizens’ Personal Data

Back in July, President Vladimir Putin signed a law (Federal Law No. 242-FZ) that compels “data operators” to store Russian citizens’ personal data only inside Russia. Previously, Russian law allowed the storage of data...more

Editorial: For Fla. Courts, Forum Selection Clause May Not Be Enough

You represent a Brazilian corporation that is entering into a joint venture with a Colombian concern. The joint venture relates to the development of a multimillion dollar wind farm in northeastern Brazil. Originally...more

Weekly Update Newsletter - August 2014 #2

In this issue: - Obama Signs Order Boosting Federal Contract Worker Rights - DoD Issues Interim Rule to Amend DFARS Foreign Commercial Satellite Services (DFARS Case 2014-D010) - Obama Administration...more

Back to School: 7th Circuit Issues Two Decisions on International Diversity Jurisdiction

Putting together all the Seventh Circuit’s decisions from the last few decades on subject-matter jurisdiction would yield an impressive textbook on the subject. The court (and Judge Easterbook, in particular) has adhered...more

D.C. Circuit Issues Ruling in Important CFIUS Case

The D.C. Court of Appeals recently issued a landmark decision in Ralls Corporation v. Committee on Foreign Investment in the United States (CFIUS), No. 13-5315, slip. op. (D.C. Cir. July 15, 2014), that could have...more

Is Your Out-of-State LLC “Doing Business” in California?

Individuals and entities, including those from outside California, who invest in or do business through an out-of-state limited liability company (“LLC”) may be surprised to find out that they have filing obligations and tax...more

Madoff Bankruptcy Decision Offers Protection for Foreign Investors

In re Madoff Securities Extends Morrison Framework to Prevent Avoidance of Purely Foreign Transfers under SIPA and the Bankruptcy Code - Applying the U.S. Supreme Court’s landmark decision in Morrison v. National...more

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

Foreign Tax-Exempt Organizations Exempt from Withholding Tax

Investment funds, including private equity funds, often receive capital contributions from tax-exempt organizations. These tax-exempt institutions may include U.S. and foreign pension funds, as well as U.S. and foreign...more

U.S. Court of Appeals Provides Long-Awaited Guidance Regarding Whether an Entity Should be Considered an ‘Instrumentality’ of a...

In a decision with significant implications regarding the application of the Foreign Corrupt Practices Act (“FCPA”), the U.S. Court of Appeals for the Eleventh Circuit has clarified the framework for determining whether an...more

FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor [Video]

In this episode I welcome back the FCPA Professor who gives his views on the Esquenazi decision, his recent book and his upcoming FCPA Institute....more

Esquenazi Appeal Confirms the Broad Reach of the Foreign Corrupt Practices Act (FCPA)

In last month’s closely watched Esquenazi decision, a U.S. court of appeal weighed in on the definition of “instrumentality” under the Foreign Corrupt Practices Act (FCPA) for the first time. The case—an appeal to the 11th...more

Eleventh Circuit Defines “Instrumentality” Under the FCPA

In a case of first impression for the US Court of Appeals for the Eleventh Circuit, the court interpreted the term “instrumentality” of a foreign government in the Foreign Corrupt Practices Act (FCPA). The court used the...more

Federal Court of Appeals Addresses Oft-Debated Definition of "Instrumentality" Under the Foreign Corrupt Practices Act

On May 16, 2014, the Eleventh Circuit Court of Appeals was the first federal appellate court to weigh in on the controversial definition of "instrumentality" under the Foreign Corrupt Practices Act (FCPA). In United States v....more

Esquenazi Part II – The Test For Determining An Instrumentality Under The FCPA

In Part I of my review of the 11th Circuit Court of Appeals decision in the Esquenazi case, I reviewed the Court of Appeals opinion. Today, in Part II, I want to drill down further and examine the test developed by the Court...more

Reminder Regarding Upcoming FATCA Deadline and Implications for Trading Agreements

The effective date under the Foreign Account Tax Compliance Act (“FATCA”) for withholding agents to begin withholding on certain U.S. source payments made to foreign financial institutions (“FFIs”) and non-financial foreign...more

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

The Physician Payment Sunshine Act Final Rule: Key Change From Proposed Rule Affecting Foreign Entities

We now have only 36 days to go until August 1, 2013, when the new data collection obligations imposed on “applicable manufacturers” and group purchasing organizations under the physician payment “sunshine” rules of the...more

21 Results
|
View per page
Page: of 1