The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
AGG Talks: Cross-Border Business Podcast - Episode 26: U.S. Enforcement Trends Targeting Foreign Pharmaceutical and Medical Device Manufacturers
Scaling Success: Hanley Energy’s Journey From Ireland to the U.S.
Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review
AGG Talks: Cross-Border Business - How Foreign Companies Can Protect Their IP and Brand in the U.S.
AGG Talks: Cross-Border Business - Navigating Business Etiquette and Intercultural Communications Around the Globe
AGG Talks: Cross-Border Business - Privacy & Cybersecurity Considerations for Non-U.S. Companies
AGG Talks: Cross-Border Business — Episode 6: Immigration Insights for Companies Expanding Into the U.S. - Part 2
AGG Talks: Cross-Border Business — Episode 6: Immigration Insights for Companies Expanding Into the U.S. - Part 1
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Economic Incentives for Foreign Companies Entering the U.S.
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
AGG Talks: U.S. Bankruptcy Basics for Foreign Investors
10 Things Lawyers Should Know About BVI Transactions
Nota Bene Episode 109: Asia Q1 Check In: China’s Emergence as the Number One World Economy and New Hegemonic Role in Asia with Paul Kim
The Evolution of Cross-Border Restructuring Processes
Nota Bene Episode 93: Navigating the New Global Cybersecurity Compliance Landscape with Scott Giordano
2025 was characterized by significant new legislation impacting private funds that in many respects preserved the status quo of many core features relevant to private equity, ongoing judicial activity shaping enforcement and...more
The Ministry of Justice published a new legislative memorandum (Draft Bill) for public comments a few days ago, which seeks to regulate the application of Israeli law to foreign dealers who target customers in Israel. The...more
Q: I am a receiver for a Delaware LLC who’s business is operated in California and Nevada. A creditor of the LLC has contacted me demanding that I turnover the proceeds of receivables I have collected, contending it has a...more
In the first of its kind, a US company with no prior connection to the United Kingdom, has financially restructured via a Part 26A Companies Act (UK) Restructuring Plan (the RP), in respect of which it also achieved Chapter...more
As 2025 ended, New York Governor Hochul vetoed legislation that would have expanded the reach of New York's Limited Liability Company Transparency Act (NY Transparency Act) to impose new filing requirements on U.S. and...more
Let’s begin with the bottom line: “In sum, we conclude that email service on the Chinese defendants is prohibited by the Hague Service Convention, and thus improper under Rule 4(f)(3).” Smart Study Co., LTD. v. Acuteye-US,...more
The NYS LLC Transparency Act (LLC TA) becomes effective on January 1, 2026, with a narrow scope consistent with the Interim Final Rule promulgated by FinCEN earlier in 2026....more
This note describes in outline the laws and taxes which currently apply to a foreign corporation establishing a business operation in the United Kingdom and the administrative requirements which need to be observed once the...more
On December 4, 2025, the United States Internal Revenue Service (IRS) published Notice 2025-75, Notice 2025-77, and Notice 2025-78 providing guidance on certain provisions that were modified as a result of the H.R. 1, P.L....more
The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election under Section 898(c)(2) and modifications to the treatment...more
The United States Internal Revenue Service (IRS) released Notice 2025‑72 (Notice) on November 25, 2025, addressing two issues arising from the repeal of the one‑month deferral election under Section 898(c)(2). Specifically,...more
Subpart F income requires U.S. shareholders of controlled foreign corporations to report certain categories of foreign income — even when no distribution is made. This article explains how Subpart F works, the types of income...more
The Internal Revenue Service (IRS) and U.S. Treasury Department have issued final regulations (T.D. 10037) (Final Regulations) under Section 4501 of the Code (the Excise Tax) that withdraw the previously proposed "funding...more
United States congressional inquiries have become an important instrument to shape policy agendas, test industry practices, influence public opinion, and apply pressure on industries and companies seen as politically...more
According to NERA, a leading consulting and expert firm, the share of foreign-based companies listed on U.S. stock exchanges has risen steadily in the last decade, from 17.4% in 2016 to 26.9% in 2025. As noted in our...more
On October 20, 2025, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released proposed regulations (Proposed Regulations) under Section 897 that would reverse prior regulations that looked...more
China’s new reporting rules will require Chinese domestic and international internet platform enterprises to submit tax-related information to Chinese tax authorities. ...more
The U.S. estate tax is a transfer tax on the value of property transferred at death. The tax applies differently depending on whether a person is considered a U.S. person or a non-U.S. person at the time of the transfer. For...more
The US Securities and Exchange Commission has announced the formation of a cross-border task force to combat fraud. While the Commission’s press release specifically referenced market manipulation and “pump-and-dump” schemes...more
The Nasdaq Stock Market LLC (Nasdaq) recently submitted proposed enhancements to its initial and continued listing standards to the US Securities and Exchange Commission (SEC), aiming to strengthen its longstanding commitment...more
A recent decision in an adversary proceeding in Delaware, arising from the Chapter 7 liquidation of Rosetta Genomics, Inc., serves as a cautionary tale for corporate officers and directors — especially those of parent...more
In an action for breach of a commercial lease agreement, related personal guaranty agreement, and fraudulent inducement filed by the property owner and landlord against a former tenant and personal guarantors, Shumaker...more
In a general legal advice memorandum dated September 8, 2025, with a release date of September 19 (the “GLAM”), the Chief Counsel’s office of the Internal Revenue Service (“IRS”) addressed the application of the US branch...more
On Sept. 5, the SEC announced the formation of a new Cross-Border Task Force to combat international market manipulation and fraud. The SEC said the task force will focus initially on investigating potential U.S. federal...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more