Law Firm ILN-telligence Podcast | Episode 76: Henrique Lopes, KLA Advogados | Brazil
International Litigation and Transactions in the Face of GDPR – A Panel Preview
The California Office of Tax Appeals (OTA) denied a request for rehearing of a July 2023 OTA opinion favorable to Microsoft Corp. that could have wide-ranging impacts for a water's edge filer in California, particularly one...more
Henrique Lopes is a partner at KLA Advogados, the ILN's member firm for Brazil. In this episode, he and Lindsay focus on the generational approaches to work post-pandemic and what aspects of the legal industry have remained...more
The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the...more
A New York intermediate appellate court upheld a New York State Tax Appeals Tribunal determination finding that International Business Machines Corp. and its combined affiliates (together, “IBM”) improperly deducted royalty...more
In the guise of clarifications relating to criminal convictions and misconduct, the Department of Labor (DOL) has proposed major amendments to Prohibited Transaction Exemption (PTE) 84-14, also known as the QPAM exemption...more
Lost in the uproar over the China Initiative that the Justice Department eventually shut down was the role of universities in ensuring compliance with disclosure requirements related to foreign affiliations. In at least some...more
Earlier this week, the Canadian government introduced the Budget Implementation Act, 2022, No. 1 (Bill) to enact measures announced in its April 7, 2022 budget (Budget). The Budget foreshadowed that the Bill would contain...more
In the wake of a recent landmark decision by a federal appellate court in regard to where climate change lawsuits should be litigated, the U.S. Court of Appeals for the Fourth Circuit has provided further guidance as to how...more
On January 24, 2022, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”). FinCEN is proposing a rule to establish a pilot program that permits certain financial institutions...more
On December 2021, the French Supreme Court acknowledged the jurisdiction of the Nanterre Civil Court in a duty of vigilance matter. On 15 Background The Duty of Vigilance for parent companies was introduced into the French...more
The Public Company Accounting Oversight Board published a proposed rule designed to create a framework for determinations to be made under the Holding Foreign Companies Accountable Act passed last year (HFCAA). That Act...more
The 2021 Canadian Federal Budget, released on April 19, 2021, proposes new rules that would fundamentally alter the interest deductibility landscape for Canadian businesses. The thrust of the new rules (referred to herein as...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
Complex intercorporate structures and related financings pose specific challenges in the cross-border insolvency context. Where a number of affiliates are liable for the debts of a common corporate enterprise, complete...more
On June 29, 2020, the Supreme Court of the United States decided Agency for International Development, et al. v. Alliance for Open Society International, Inc., et al., No. 19-177, holding that Congress may lawfully condition...more
The Paycheck Protection Program Flexibility Act of 2020 (the “PPP Flexibility Act”) was signed into law by President Trump on June 5, 2020, which provides Paycheck Protection Program (the “PPP”) loan borrowers additional time...more
The U.S. Small Business Administration (SBA) recently issued an Interim Final Rule that confirms that when calculating the number of employees of an entity for purposes of determining eligibility for a PPP loan, an entity...more
In answer to a question hanging over the PPP loan program since its inception, the SBA on May 18 offered a safe harbor to borrowers who did not originally count its foreign employees, and those of its affiliates, in its loan...more
I. Introduction - The BE-10 benchmark survey of U.S. Direct Investment Abroad is a survey conducted every five years by the Bureau of Economic Analysis (the "BEA") of the U.S. Department of Commerce in order to obtain...more
Originally published on April 14, 2020. Last updated as of the morning of May 15, 2020. Since the enactment of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) on March 27, 2020, the U.S. Small...more
Late on May 5, 2020 the Small Business Administration (SBA) issued another round of Frequently Asked Questions (FAQs) that extended the Safe Harbor Deadline to return Paycheck Protection Program (PPP) loan funds from May 7,...more
- The BEA requires all U.S. persons that own or control more than 10 percent of the voting securities of a “foreign” business enterprise to file a report on its BE-10 Benchmark Survey of U.S. Direct Investment Abroad for the...more
In our post of April 4, we advised there was an ambiguity between the CARES Act and subsequent guidance issued by the Small Business Administration (SBA) on whether employees of foreign affiliates of applicants are considered...more
The Bureau of Economic Analysis (BEA) conducts various surveys of U.S. multinational companies and U.S. affiliates of foreign enterprises to generate statistical information regarding the global business activities of U.S....more