News & Analysis as of

Foreign Subsidiaries

Recent Tax Court Decision in Crestek – a Cautionary Tale for U.S. Companies with Foreign Subsidiaries

by Fenwick & West LLP on

In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S. parent company and its controlled foreign corporations constitute “United States...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

by Dorsey & Whitney LLP on

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

Saudi Council of Ministers Approves 100% Foreign Ownership of Engineering Consultancies

by Jones Day on

Currently, Saudi Arabian law permits foreign direct investment in engineering consultancies operating in the private sector only through a professional company licensed by the Ministry of Commerce and Industry ("MOCI")....more

Eaton v. IRS: Tax Court determines IRS abused its discretion in cancelling two APAs

by DLA Piper on

The Tax Court in Eaton Corporation and Subsidiaries v. Commissioner, T.C. Memo, 2017-147 determined that the IRS abused its discretion in cancelling two unilateral advanced pricing agreements (APAs) covering the transfer of...more

Shares of Foreign Subsidiaries

by Allen Matkins on

I expect that little or no thought is given to the possible application of California’s Corporate Securities Law of 1968 when a corporation incorporates a subsidiary under the laws of a foreign country. However, the issuance...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

Foreign Investment Reporting to the United States: In-Bound Investment into the United States Specific Survey Report Forms 5-Year...

by McNair Law Firm, P.A. on

The U.S. Department of Commerce, Bureau of Economic Analysis (BEA), conducts seven (7) mandatory surveys to collect information on direct investment. These seven surveys consist of an initial survey for any new in-bound...more

Global Transportation Finance Newsletter - June 2017

by Vedder Price on

So, what is LIBOR? LIBOR—the London Interbank Offered Rate—is one of the most ubiquitous benchmarks for determining short-term interest rates in bank (and other) lending. LIBOR rates are short-term fixed rates quoted for...more

O.W. Bunker: Some Modest Considerations

by Vedder Price on

Vessels cannot sail without fuel. This industry truth is recognized in contracts and under U.S. maritime law. In fact, enabling ship operators to efficiently obtain fuel is so important that U.S. maritime law purports to...more

The Long Arm of U.S. Sanctions: Penalty Imposed Against Canadian Subsidiary of U.S. Subsidiary of Japanese Company

by Bass, Berry & Sims PLC on

On June 8, the Office of Foreign Assets Control (OFAC) announced a monetary penalty against American Honda Finance Corporation (American Honda) for alleged violations of the Cuban Assets Control Regulations (CACR), the...more

Why should Qatari, Saudi and UAE organizations care about the European Union’s new General Data Protection Regulation?

by Latham & Watkins LLP on

The compliance world will change dramatically for a number of GCC organizations on 25 May 2018. In just over one year’s time GCC organizations that...more

Where Federal Tax Reform Goes, Will State Taxes Follow?

by Ballard Spahr LLP on

With Republicans in control of both the White House and Congress, comprehensive federal tax reform likely is on the horizon. Both the tax reform plan outlined by President Donald J. Trump during his campaign (the Trump Plan)...more

Grey Marketing – Still Not Black and White in Canada

by Smart & Biggar on

Grey marketing, sometimes referred to as “parallel importation”, is the diversion of goods, originally intended for sale only in certain countries, to other countries where they were not intended to be sold. The goods are not...more

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

by Jones Day on

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

Explanation of J. Crew “back-door” provision and proposal for how lenders might address this in their documentation.

by King & Spalding on

Recently, J. Crew used a “back-door” provision in its credit facility to transfer approximately $250 million worth of intellectual property (“IP”) to an unrestricted subsidiary with the aim of borrowing against the...more

Investment Treaty Arbitration: How Multinationals Can Structure Their Investments to Obtain Treaty Protection

by King & Spalding on

In a previous article, we explained how a U.S.-based company that had established a subsidiary abroad could benefit from protections against unfair conduct of a foreign State that are found in most bilateral investment...more

FCPA: 2016 in Review Webinar

by Bryan Cave on

Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

by Bass, Berry & Sims PLC on

- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

Update on Sapin II law

by White & Case LLP on

On 8 November 2016, the French Parliament passed a law targeting transparency, anti-corruption and the modernisation of the economy, known as the Sapin II Law. This law entered into force on 11 December 2016. Consequently,...more

So You’re Going Global! Five Employment Basics for U.S. Companies Expanding Overseas

Your company is doing well in the United States, and you are looking to expand internationally. That can be a very exciting time! But besides the practical logistics (e.g., Do I need to set up a subsidiary to hire someone...more

Following CFIUS Recommendation, President Obama Blocks Chinese Acquisition of US-German Semiconductor Equipment Manufacturer

by Dechert LLP on

President Obama issued an executive order on December 2, 2016 blocking the sale of the U.S. business of Aixtron SE (“Aixtron”), a German semiconductor manufacturer, to a German subsidiary of a Chinese fund, Fujian Grand Chip...more

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

by Seyfarth Shaw LLP on

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

Anti-bribery compliance in India: Both sword and shield

by Dechert LLP on

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

A Comparison of Trump and House GOP Tax Reform Proposals

by Holland & Knight LLP on

With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more

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