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Akin Gump Strauss Hauer & Feld LLP

US Presidential Elections 2024—What is at Stake for Swiss Companies and Investors?

The November U.S. Presidential electoral campaign is in full swing. Since President Joe Biden ended his reelection bid and Vice President Kamala Harris secured the Democratic Party nomination, polls now show a tight race...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

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In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

Conyers

Norway Bulletin 2024

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We are pleased to bring you the Conyers Norway Bulletin for 2024, in which we highlight developments affecting Bermuda incorporated companies in the Norwegian market over the past year. The Oslo Børs continues to serve as...more

Pillsbury - Propel

Nevada Doesn’t Have Corporate or Personal Income Taxes: Should I Form There?

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As of the date of this article, Nevada does not have a corporate income tax or a personal income tax. Contrast Nevada’s 0% with California’s corporate tax rate of 8.84% and top individual income tax rate of 13.3% and...more

International Lawyers Network

Establishing a Business Entity in the United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more

Walkers

Ireland | Chambers 2024 Global Practice Guide on Securitisation

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1. Specific Financial Asset Types - 1.1 Common Financial Assets - A wide range of asset classes have been securitised by Irish special purpose entities (SPEs): residential mortgages; commercial mortgages; auto loans;...more

Barnea Jaffa Lande & Co.

Israeli High-Tech: “Angels Law” Grants Tax Benefits to Investors

The Israeli legislature promulgated a new Angels Law at the end of July, with the goal of preserving Israel as an attractive hub for investments in high-tech companies by granting various tax incentives. (This temporary order...more

Morrison & Foerster LLP

Protecting Tax Assets – Considering an NOL Rights Plan - UPDATED

A corporation’s net operating losses (NOLs)are important assets that can be used to reduce future taxable income. But certain changes in a corporation’s ownership can significantly reduce the value of those NOLs....more

Goodwin

The South Korean K-Chips Act and Its Impact on International Companies and Investors

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For investors in enterprises in the Korean semiconductor industry and other national strategic industries, a new tax bill has been passed that (i) increases the base tax credits received by these enterprises to 25% (if...more

Holland & Knight LLP

2023 Mexican Tax Considerations for Mexican and Foreign Taxpayers

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Although no major tax reform was adopted in Mexico as part of the 2023 Economic Package, changes at an international level and some being brought at the regulatory level could have significant implications for different...more

Rivkin Radler LLP

An S Corporation’s Sale of Real Property Following the Death of Its Shareholder

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Don’t Do It- There are certain generally accepted “dos and don’ts” of which almost every investor is certainly aware. For example, do not put all your eggs in one basket; if an investment seems too good to be true, stay...more

A&O Shearman

20 Questions for Qualifying Asset Holding Companies (QAHCs)

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The Finance Act 2022 (FA22) has introduced a new regime for qualifying asset holding companies (“QAHCs”). The new regime, which came into force on 1 April 2022, offers qualifying companies a wide range of tax benefits,...more

International Lawyers Network

Establishing A Business Entity In The United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...more

Eversheds Sutherland (US) LLP

Biden’s second (attempted) bite at the private equity apple: Key 2023 Green Book proposals impacting private equity funds and...

On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the Budget) followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals....more

Jones Day

2021 Transactional Year in Review and 2022 Forecast: Until Enacted or Withdrawn, Proposed U.S. Tax Reform Continues to Have an...

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Since early 2021, Congress has been working on legislation that would alter the U.S. tax laws and potentially have a significant impact on M&A and private equity transactions....more

Latham & Watkins LLP

Non-Plain Vanilla Questions About Taxation of Plain Vanilla Convertible Debt

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Convertible debt is exceptionally attractive to investors in volatile markets because it offers the security of a bond with the upside of equity. That is why convertible debt was one of the strongest asset classes during the...more

Rivkin Radler LLP

Disposing Of Assets Under The Ways and Means Committee’s Proposals

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First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more

Dechert LLP

UK Qualifying Asset Holding Companies: How Will the Proposals Impact Debt Funds?

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The structure is a simplified version of how a typical European fund might be established in Luxembourg where currently we would typically use a downstream Luxembourg SARL or securitisation vehicle as the intermediate...more

International Lawyers Network

Establishing A Business Entity In The United States

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...more

White & Case LLP

Foreign direct investment reviews 2020: A global perspective - India

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Government approval is required for all foreign investments from countries sharing a land border with India - Non-residents investing in India are required to comply with India's Foreign Direct Investment (FDI Policy and...more

Goodwin

Luxembourg 2021 Budget: An Overview Of the Main Tax Amendments which Impact The Fund Industry

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The much-awaited Luxembourg state budget for FY 2021 has finally been tabled before the Chamber of Deputies. Delayed due to the ongoing COVID-19 pandemic, the Luxembourg government published bill number 7666 on 14 October...more

Gerald Nowotny - Law Office of Gerald R....

[Webinar] En mi Viejo San Juan - Puerto Rican Tax Incentives - October 6th, 2:00 pm - 3:00 pm EST

What we'll cover: - What is Act 22? - What is Act 20? - Requirements for U.S. Taxpayer - Planning Examples...more

Manatt, Phelps & Phillips, LLP

Founder’s Stock: Vesting and Acceleration

Founder’s stock refers to the equity granted, typically in the form of common stock, to founders of a company for their preformation efforts in building the company. This common stock is sold to founders at a nominal value at...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

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On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more

Farrell Fritz, P.C.

When Limited Liability Yields To Transferee (Personal) Liability

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“Limited Liability” The experienced or well-informed investor recognizes that there is an element of risk in every business venture. They understand that the cash or other property they have contributed to the venture may be...more

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