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
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
National Security Podcast: US Government Zeros in on China
Nota Bene Episode 85: Trade Wars - The Rise of Export Controls and the Impact on the Growth of Technology with Reid Whitten
Nota Bene Episode 80: South Korea’s Bellwether on the Pandemic Market Recovery with Paul Kim
On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more
Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...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
In President Biden’s recent State of the Union Address, he called on corporations and wealthy taxpayers to pay their “fair share” through proposals to end tax breaks for private jets, further limit deductions for executive...more
The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more
The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more
With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically,...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (“IRA”) into law. While much of the legislation is geared towards climate change mitigation, clean energy, and provisions to promote health care...more
On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022 (the “Act”), which was signed into law by President Biden on August 16, 2022. Alongside sweeping changes to energy, environmental and...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock (the Buyback...more
The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more
Comprehensive tax reform is moving rapidly, and both the House and the Senate have proposed their own versions of tax reform. Our International Tax and Tax Policy & Regulation Groups investigate the differences between the...more
The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more
Tribunal Upholds Personal Liability of LLC Members for Sales Tax - The New York State Tax Appeals Tribunal has affirmed the determination of an Administrative Law Judge that a member of a limited liability company...more