The U.S. Environmental Protection Agency (EPA) on Sept. 6, 2024, announced the availability of $6.5 billion in Water Infrastructure Finance and Innovation Act (WIFIA) funding and $1 billion in State Infrastructure Financing...more
Since Congress first introduced the Corporate Transparency Act (“CTA”) and the beneficial ownership information reporting framework in January 2021, much of the focus has been on the specific reporting requirements that now...more
What is the purpose of the Domestic Content Bonus Credit? The Inflation Reduction Act (IRA) introduced the Domestic Content Bonus Credit to provide an additional credit amount to taxpayers that meet its requirements. The...more
The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more
On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more
Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more
On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more
On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more
The Commission recently reversed the ALJ’s determination that the economic prong of the domestic industry requirement was satisfied and thereby found that there had been no section 337 violation in Certain Replacement...more
On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more
I. Types of business entities - As a general rule, foreign equity is allowed to conduct and participate in business in the Philippines, through any of the following modes: 1. By investing in a domestic stock...more
Beginning on January 1, 2024, certain reporting companies are now required to comply with the disclosure requirements of the Corporate Transparency Act (CTA). This law aims to enhance transparency in corporate ownership,...more
Each year, corporations that have employees who exercise incentive stock options (ISOs) as described under Section 422(b) of the Internal Revenue Code must file a Form 3921 with the IRS for each transfer of stock to those...more
Effective January 1, 2024, companies must disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) within the United States Department of Treasury. The reporting requirement is part of the U.S....more
This advisory provides a general summary of the Corporate Transparency Act and its requirements and is not intended to, and does not, provide legal, compliance or other advice to any individual or entity....more
As we approach the end of 2023, nearly all privately owned businesses operating in the United States must prepare for the implementation of the Corporate Transparency Act (“CTA”), a federal law taking effect on January 1,...more
WHAT: The Space Force’s Space Domain Awareness (SDA) Tools, Applications, & Processing (TAP) Lab is kicking off its inaugural Project Apollo cohort on October 26, 2023. Open to all domestic companies, Project Apollo will be...more
The Financial Crimes Enforcement Network (“FinCEN”) has published a new Small Entity Compliance Guide (“Guide”) for compliance with the Beneficial Ownership Information Reporting Rule (“Reporting Rule”), 31 CFR 1010.380. The...more
As the United States carries out projects funded by the Infrastructure Investment and Jobs Act, the Inflation Reduction Act, and the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act, the manufacturing...more
On January 1, 2024, the Corporate Transparency Act (the “CTA”) will go into effect. The CTA is a U.S. law (31 U.S. Code § 5336), enacted January 1, 2021, that aims to combat money laundering and other illicit activities. The...more
Yesterday's post mentioned mentioned Chapter 17 of the California General Corporation Law which governs service of process in addition to the provisions of the California Code of Civil Procedure. Corporations Code Section...more
On July 31, 2023, a divided Michigan Supreme Court in Vectren Infrastructure Services v. Michigan Treasury issued an important decision in favor of the state, ruling that an out-of-state taxpayer could not reduce its tax by...more
In Short - The Situation: In the last month, two courts in the Ninth Circuit allowed human rights focused cases to proceed beyond the pleading stage. These cases seek to impose liability on U.S.-based companies for alleged...more
In Mallory v. Norfolk Southern Railway Co., Robert Mallory (a Virginia resident) sued his former employer, Norfolk Southern (a Virginia-based railroad), over his alleged exposure to toxic chemicals while working for Norfolk...more