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On 4 December 2025, the UK Government published the Finance Bill, which contains updated draft legislation relating to carried interest. On the same date, HMRC published an overview of the carry legislation, and draft...more
On November 18, 2025, the OECD adopted the “2025 Update to the OECD Model Tax Convention” (Update), which includes broad-ranging updates to the OECD model treaty (Model Treaty). The most significant updates to the...more
This episode of Tech Talks outlines why intercompany licensing—clear ownership, licensees, and exclusive rights—is vital for operations and litigation standing. It flags exit tax and transfer pricing exposure tied to DEMPE...more
Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual...more
Austria has approved the signing of Double Tax Treaty with Oman - On 24 September 2025, Austria has authorized the signing of the Double Tax Treaty (DTT) with Oman. The countries reached consensus on the draft DTT in March...more
Before the 2017 Tax Act, owners of a two-or-more-owner business should generally have elected that such business be an LLC taxable as a partnership. After the 2017 Tax Act, that advice remains sound. However, for a business...more
The One Big Beautiful Bill Act (“BBB”) made permanent several temporary provisions of the Tax Cuts and Jobs Act of 2017 (“TCJA”), while also introducing changes to numerous items related to individual income tax. Several...more
Choosing the right corporate structure is one of the first—and most important—decisions a business owner makes. In a recent conversation, Shawn McClelland and Alexa La Barbiera of Mandelbaum Barrett PC’s Corporate Practice...more
In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach to determining the ‘place of effective management’ (POEM) in the context of the UK’s double tax...more
In June, the Appellate Court of Illinois upheld an assessment of over $314 million against Sam’s Club for unpaid county cigarette excise taxes, including a 10% late fee, a 25% penalty, and accrued interest. The assessment...more
1. Types of Business Entities - When entering the Romanian market, foreign investors have the option of incorporating a new legal entity with a Romanian legal personality, or setting up a unit of a foreign mother...more
Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more
1 TYPES OF BUSINESS ENTITIES - There are several forms of business entities in Denmark and there are a wide range of possibilities for establishing a business entity in Denmark. The most suitable entity depends on a...more
This inaugural issue of ArentFox Schiff’s publication on international mining, energy, and infrastructure disputes aims to provide insights and practical information to general counsels and senior executives of companies...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER MICHIGAN LAW - I. STANDARD FORMS OF AGREEMENTS - A. Offers to Purchase that are accepted by sellers are the typical form of purchase contract for residential properties. The...more
Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more
As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
1. Types of business entities - Investors may choose from the following forms of corporate structure: - Limited liability company - Joint-stock company - Limited liability partnership - General partnership -...more
Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER ECUADOREAN LAW - Real Estate acquisitions typically involve several key stages, ultimately leading to the transfer of ownership. The most common phases include: 1) Initial...more
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
Companies required to use “box 11” of Form W-2 in 2023 to report either payments of nonqualified deferred compensation (deferred compensation) or FICA taxation of unpaid deferred compensation may soon be challenged by...more
There is a little-known asset – personal goodwill – that is present in certain types of businesses and can potentially provide a significant tax benefit when identified as part of a transaction. This article will clarify what...more