Understanding FOCI Mitigation
Scaling Success: Hanley Energy’s Journey From Ireland to the U.S.
Legal Alert | Japan is Primed for Increased Foreign Direct Investment
Ask a CFIUS Expert: Is Crypto Spying on Us?
AGG Talks: Cross-Border Business Podcast - What Foreign Investors Need to Know About U.S. Independent Contractor Laws
Hot Topics in International Trade-Braumiller Law Group-FDI Into Mexico from China
Welcome to “Lowenstein Africa Presents: Venture Voices”
AGG Talks: Cross-Border Business Podcast - Episode 13: Tips and Tricks for Foreign Investors Employing U.S. Personnel
Legal Challenges Part 1 – Setting Up Your Startup for Success
Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review
AGG Talks: Cross-Border Business - How Foreign Companies Can Protect Their IP and Brand in the U.S.
AGG Talks: Cross-Border Business - Navigating Business Etiquette and Intercultural Communications Around the Globe
AGG Talks: Cross-Border Business - Privacy & Cybersecurity Considerations for Non-U.S. Companies
AGG Talks: Cross-Border Business — Episode 7: Trans-Pacific Business: Australia and the U.S. - Part 2
AGG Talks: Cross-Border Business — Episode 7: Trans-Pacific Business: Australia and the U.S. - Part 1
The Now and Next in International Trade: 5 Fast Facts About CFIUS – a National Security Agency You Should Know
Contratación para el Desarrollo de Infraestructura del Agua
AGG Talks: Cross-Border Business - Enterprise Ireland and U.S. Market Entry
AGG Talks: Cross-Border Business - Economic Incentives for Foreign Companies Entering the U.S.
Law Firm ILN-telligence Podcast | Episode 78: Diego D'Odorico, SyLS | Argentina
Letter from the Editors - Words are very powerful and the language we use often frames a discussion. For example, the term “shareholder activist” sounds like a consumer friendly person who has everyone’s best interests at...more
In a recent decision, Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, the U.S. Tax Court declined to follow Revenue Ruling 91-32, and held that gain on the sale of an interest in an operating...more
US Tax Court decision may facilitate tax-efficient investment structures for non-US investors investing in US operating partnerships, directly or through investment funds....more
The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more
On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more
On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more
In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more
A foreign investor, not engaged in a U.S. trade or business, can sell stock in a U.S. corporation without fear of U.S. tax liability (with the notable exception of stock in certain U.S. corporations heavily invested in U.S....more
Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more
A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more
Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more
On August 25, 2014, the Indiana Supreme Court issued its decision in Indiana Department of State Revenue v. Caterpillar, Inc., holding that the plain meaning of the Indiana tax statutes prohibited the company from increasing...more