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Subsidiaries Cross-Border Transactions

Dorsey & Whitney LLP

Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property

Dorsey & Whitney LLP on

Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as...more

Latham & Watkins LLP

Are Private Equity Bank Buyouts Set to Soar?

Latham & Watkins LLP on

Ten years ago, a PE investment in a European bank would have been a rare occurrence. However, more recently, PE firms have deployed capital in the banking sector, encouraged by changing regulatory perceptions of PE bidders....more

White & Case LLP

Brexit preparedness for financial services: the German response

White & Case LLP on

The House of Commons recently rejected the Withdrawal Agreement. While the UK Parliament is still debating how to leave the EU, a hard Brexit remains an option. To prepare for this possibility, the UK, EU Commission and EU27...more

White & Case LLP

2018 Half-year in review: M&A legal and market developments

White & Case LLP on

We set out in the attached Newsletter a number of interesting English court decisions and market developments which have taken place in the second half of 2018 and their impact on M&A transactions. This review looks at these...more

Latham & Watkins LLP

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Latham & Watkins LLP on

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Pillsbury Winthrop Shaw Pittman LLP

CFIUS and China: Separating Fact from Fiction

No, the Committee on Foreign Investment in the United States has not put a halt to acquisitions of U.S. companies by China-based purchasers. Three recently cleared transactions illustrate that CFIUS is not standing in the...more

Dorsey & Whitney LLP

Cross-Border Loan Transactions: Supplementing Canadian Law Governed Loan Documents with Collateral and Guaranty Documents Governed...

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Many cross-border loan transactions involve subsidiaries that are organized in the United States and/or U.S. based collateral. To the extent that the underlying loan is made to a Canadian borrower by a Canadian lender, these...more

Seyfarth Shaw LLP

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

Katten Muchin Rosenman LLP

Bridging the Week - October 2016 #2

Alleged Flash Crasher Navinder Sarao Loses Final Effort to Avoid US Extradition: Navinder Sarao, the London-based futures trader who in April 2015 was criminally charged with contributing to the May 2010 “Flash Crash,” is now...more

K&L Gates LLP

EU Adopts a Parent-Subsidiary Directive Amendment on Hybrid Loans

K&L Gates LLP on

On July 8th 2014, the European Union’s Economic and Financial Affairs Council (ECOFIN) adopted an amendment to the Parent-Subsidiary Directive (PSD). This amendment is targeted at cross-border hybrid loans and aims to...more

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