Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Bill on Bankruptcy: Big Time Lawyers Pricing Themselves Out
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more
Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform. On August 1, 2018, proposed...more
On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a...more
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-16 (the Notice) providing additional guidance regarding the transition tax in section 965 of the Internal Revenue Code of...more
A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified...more
In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more
Mean Girls v. The Right of Publicity: Lessons Learned From the Lohan and Gravano Lawsuits - On September 1, 2016, a New York appellate court ended two closely watched right of publicity lawsuits brought by Lindsay...more
In a recent news conference President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more
There is no love lost between the U.S. Treasury and U.S. companies seeking offshore tax homes. Absent congressional action to stem the inversion tide, the Treasury and IRS are left to flex their regulatory and administrative...more
In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more
The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more
Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more
IRS audits signal focus on Section 409A compliance; Revenue Ruling makes certain nonqualified options and stock appreciation rights more attractive for offshore entities. The IRS has begun its limited audit initiative...more