Overview- The City Code on Takeovers and Mergers (the “Code”) contains a number of traps for the unwary, not least that it can extend to unlisted companies or companies with overseas listings, with seemingly limited nexus...more
On 24 April 2024, the UK Takeover Panel published PCP 2024/1 ("PCP 2024/1"), in which it is consulting on a significant narrowing of the types of companies that will be subject to the Takeover Code (the “Code”) - i.e., as...more
This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
The Hatch-Waxman Act provides a cause of action for infringement based on the submission of an abbreviated new drug application (ANDA) to FDA. 35 U.S.C. § 271(e)(2). Following the Supreme Court’s ruling in TC Heartland LLC v....more
In a recent Board of Tax Appeals Case, taxpayers contested the Department’s assessment of personal income taxes, asserting that they were not Ohio residents. See Anthony R. Joy & Robin E. Miller, (et. Al.), v. Jeffrey A....more
The New York Department of Taxation and Finance has finally provided guidance regarding telecommuting tax liability for nonresident employees working outside of New York because of the COVID-19 pandemic. In short: employees...more
Since the outset of the COVID-19 pandemic and work-from-home mandates, New York employers and their nonresident employees have been waiting for the Department of Taxation and Finance to address the million-dollar question: Do...more
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. Although there is a double tax treaty between the US and the UK...more
Over the last month or so, most of the nation’s tax practitioners have been devoting an extraordinary amount of time to analyzing the recently enacted changes to the Code, to understanding the resulting consequences, and to...more
Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more
Many M&A transactions are negotiated across state lines. When an out-of-state lawyer misrepresents facts in a phone call and email to a lawyer in California, do those communications render the foreign lawyer amenable to suit...more
Hybrid US S-Corporation eligible for participation exemption. Refund practice of taxes withheld remains to be seen. In a recent judgment (file no. I R 48/12), the German Federal Fiscal Court has commented on Art. 1...more
In a recent unanimous decision, the New York Court of Appeals determined that a taxpayer domiciled in New Jersey was not a New York resident because he did not maintain a permanent place of abode in the state. The Court...more