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A&O Shearman

Pensions: what’s new this week - September 23, 2024

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Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions. ...more

Jenner & Block

Energy Infrastructure Funding Opportunities under the Infrastructure Law and Inflation Reduction Act

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The Infrastructure Investment and Jobs Act (IIJA), signed into law in November 2021, and the Inflation Reduction Act (IRA), signed into law in August 2022, are both recent landmark climate-related legislation aimed at...more

Patterson Belknap Webb & Tyler LLP

Cross-Border Issues for Founders with U.S. Companies

We encounter many founders who have based their enterprises in the U.S., but who are not U.S. citizens or permanent residents, or who may have other significant cross-border ties such as close family living outside the U.S....more

Goodwin

Luxembourg’s Residential Lease Reform: What Does It Mean for Real Estate Investments?

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The Bill of Law No. 7642 (referred to here as the Residential Lease Law) entered into force on 1 August 2024. The Residential Lease Law modifies the residential-leasing regulations in Luxembourg....more

Morris, Manning & Martin, LLP

IRS Provides Two-Year Window to Appeal ERC Denials

Tens of thousands of businesses have received letters from the IRS denying their Employee Retention Credit (ERC) claims. The IRS is in the process of sending many more ERC denial letters. Previously, the IRS only allowed 30...more

Winstead PC

The Corporate Transparency Act Requires Reporting of Beneficial Owners

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The Corporate Transparency Act (the "CTA") became effective on January 1, 2024, requiring many corporations, limited liability companies, limited partnerships, and other entities to register with and report certain...more

Conyers

日本企業のケイマン諸島持株会社上場

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日本の音響制作会社のBloomZは最近、Nasdaqでそのケイマン諸島持株会社を上場しました。弊事務所は日本の事業会社のケイマン諸島持株会社によるIPOに従事しており、日本企業が香港またはNYSE/Nasdaqで上場する際にかかるケイマン諸島持株会社ストラクチャーを採用することがなぜ有益なのか、本稿でご説明したいと思います。...more

Conyers

Listing Japanese Companies Using Cayman Holding Companies

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Having recently completed the listing on Nasdaq of BLOOMZ, the Cayman Islands incorporated holding company of a Japanese audio production company, and being currently engaged to act on a number of IPOs of Cayman Islands...more

Amundsen Davis LLC

You Filed Your Beneficial Ownership Information Report, But Is it Right? An Analysis of Substantial Control

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You are likely now aware of the Financial Crimes Enforcement Network's (FINCEN) new Corporate Transparency Act in effect as of January 1, 2024, that requires domestic entities (and foreign entities qualified to do business in...more

Goodwin

August 2024 German Court Ruling Reshapes Tax Strategy for Luxembourg Funds

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On August 22, 2024, Germany’s Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation, particularly for Luxembourg-based funds investing in Germany....more

Proskauer - Tax Talks

California FTB Releases Updated Proposed Regulations on Market-Based Sourcing Rules – Implications for Asset Managers

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On September 13, 2024, California’s Franchise Tax Board (“FTB”) released updated proposed regulations (“Draft Regulations”), which would amend the rules regarding market-based sourcing for sales other than sales of tangible...more

Eversheds Sutherland (US) LLP

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

Smith Anderson

Franchise Tax Refund Opportunity

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Corporations subject to North Carolina’s franchise tax have an opportunity to seek refunds of their 2021 and 2022 franchise taxes but should act promptly to preserve their rights....more

Walkers

Pillar Two - Global Minimum Taxation and Ireland

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The Irish Pillar Two rules apply to in-scope entities for accounting periods commencing on or after 31 December 2023. Following the GloBE Rules and the EU's Minimum Tax Directive, the rules introduce a minimum effective tax...more

Pullman & Comley - Labor, Employment and...

The Newest Wage Hour Risk in Connecticut: Election Poll Workers

A new Connecticut law went into effect this year creating early voting procedures for the first time in Connecticut.  The law, Connecticut General Statutes § 9-163aa, provides that before each election, a period of early...more

Holland & Knight LLP

Treasury, IRS Release Proposed Regulations Under Section 30C

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The U.S. Department of the Treasury and IRS on Sept. 18, 2024, released proposed regulations under Section 30C of the Internal Revenue Code regarding the Alternative Fuel Vehicle Refueling Property Credit. The proposed...more

Pierce Atwood LLP

New Guidance for Clean Electricity Low-Income Communities Bonus Program

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The U.S. Department of the Treasury recently issued proposed regulations to implement the Clean Electricity Low-Income Communities Bonus Program, which was created under the Inflation Reduction Act to incentivize clean energy...more

Fleurinord Law PLLC

Lessons from the Hunter Biden Tax Evasion Scandal

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Would you risk prison time to avoid paying taxes? That’s a question Robert Hunter Biden, publicly known as "Hunter Biden," may have asked himself when he faced serious tax evasion charges recently. While the case...more

Sheppard Mullin Richter & Hampton LLP

Lights, Camera, Tax Breaks: California’s Updated Film Incentives

In a state where the sun always shines, California’s film tax credits seem to be the script for success. On July 10, 2023, Governor Newsom signed legislation to extend and expand California’s $330 million-a-year Film and TV...more

Cozen O'Connor

Drafting Partnership Agreements: Ensuring You Get the Returns You Bargained For

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PIP (partners' interests in the partnership) allocations are very commonly used in partnership agreements. For this reason, Investors and managers should understand the basics of PIP allocations and whether and when they...more

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Preliminary Data/IRA Energy Efficient Home Improvement Credits: Congressional Research Service Report

The Congressional Research Service (“CRS”) issued a September 16th report titled: Preliminary Data on the IRA Energy Efficient Home Improvement Credit (“Report”). CRS serves as shared staff to Congressional Committees...more

McDermott Will & Emery

Weekly IRS Roundup September 9 – September 13, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9, 2024 – September 13, 2024....more

Proskauer - Tax Talks

The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs

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On September 3, 2024, Senator Elizabeth Warren (D-MA) sent a letter to the Internal Revenue Service (the “IRS”) urging it to “increase enforcement scrutiny of REITs, especially large health and hospitality REITs that may be...more

Husch Blackwell LLP

Planning for Retirement Benefits Post-Secure Act

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On July 18, 2024, the Internal Revenue Service (IRS) issued final regulations updating the required minimum distribution (RMD) rules. The final regulations reflect changes made by the Setting Every Community Up for Retirement...more

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