News & Analysis as of

Energy Newsletter - October 2015

FERC Shares Best Practices for Stakeholder Outreach in Gas Project Permitting - The dramatic increase in domestic energy production over the past several years has resulted in the involvement of the Federal Energy...more

[Webinar] Tax Planning for Investments Into Brazil - Oct. 14th, 12:00pm ET

Please join us on Wednesday, October 14th at 12:00pm EST for an in-depth joint presentation by tax attorneys, Jeffrey Rubinger of Bilzin Sumberg and Fernando Martins of WFaria Advogados on the cross-border tax considerations...more

Angola's New Private Investment Law

On 11 August 2015, Angola's New Private Investment Law ("NPIL") came into force on its publication in Angola's Gazette, repealing the previous 2011 law. Like its predecessor, the NPIL sets out the rules applicable to...more

CFPB Obtains Injunction Against World Law Group

The CFPB recently obtained preliminary injunctions against debt-reduction company World Law Group, its affiliates and its owners, thereby freezing the company’s assets and stopping all further operations pending the outcome...more

Successful Strategies for Doing Business in Asia: Taiwan (Updated)

WHAT ROLE WILL THE GOVERNMENT OF TAIWAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Three types of Taiwan government approval requirements may be relevant to direct foreign investment in Taiwan: •...more

Successful Strategies for Doing Business in Asia: Singapore (Updated)


Successful Strategies for Doing Business in Asia: Philippines

WHAT ROLE WILL THE GOVERNMENT OF THE PHILIPPINES PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The following Philippine government agencies are involved in approving and/or regulating foreign direct...more

New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

Earlier this week the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations...more

Successful Strategies for Doing Business in Asia: Indonesia (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF INDONESIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The existing Indonesian Investment Act is Law No. 25 of 2007, passed by the Indonesian House of Representatives...more

Draft Legislation Proposes Favorable Treatment for Intellectual Property Transferred to the United States

On July 29, Representatives Charles Boustany, Jr. (R-La.) and Richard E. Neal (D. Mass.) introduced draft legislation to the House Ways and Means Committee that would provide favorable tax treatment on certain intellectual...more

Tax Policy Update

NUMBER OF THE WEEK: 1,462. The total number of comments received by the Senate Finance Committee’s five bipartisan tax reform working groups in response to the committee’s request for public input on overhauling the nation’s...more

Tax Policy Update

NUMBER OF THE WEEK: 6.5 percent. The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 (S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY)...more

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

Kazakhstan’s Law on Legalisation of Property

Legalisation allows release from liability and legitimises the turnover of property. The Law on Amnesty of Kazakhstan Citizens, Repatriates (Oralmans), and Individuals Having Kazakhstan Permanent Residence Permit in...more

If I Had a Hammer – A Creative Method for Repatriating Offshore Corporate Profits

In this era of corporate inversions, there seems to be a lot of mud-slinging going around. Congress and the current Presidential administration would like to label large multi-national corporations as traitors. Somewhere...more

China Business Series: Repatriation of Funds out of China

China imposes controls on the inflow and outflow of foreign exchange. Given the involvement of State Administration of Foreign Exchange and various other governmental agencies in the process, repatriating funds from China can...more

Doing Business in Canada: E-Commerce

E-COMMERCE - Canada has a vibrant Internet community. Because of the great expansion of the Internet in Canadian homes and businesses, Canada and its provinces have, in recent years, regulated Internet activity and...more

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Market Entry: United Arab Emirates (Dubai and Abu Dhabi)

The United Arab Emirates (UAE) is a federation of seven Emirates established by a constitution that was promulgated in 1971. Abu Dhabi is the largest of the seven Emirates by geographic size and holds most of the hydrocarbon...more

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