Everything Compliance-Episode 12
On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more
In recent years, the UAE has continuously updated its legal framework to enhance regulatory oversight and adapt to global financial trends. One significant development is the amended Federal Decree-Law No. 14/2018 on the...more
This note considers the current state of the law in Hong Kong with respect to foreign illegality and whether it can set aside defences of bona fide purchaser for value without notice or change of position, in the context of...more
The euro tumbled on Monday amid heightened political and policy uncertainty in the EU, following the European elections....more
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
It was about two years ago I recall writing an article on the QUAD, whose members are the U.S., India, Australia, Japan. It was truly a head scratcher to me as to just how India, Modi specifically, was able to navigate...more
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
Are all foreign currency gains taxable? No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more
Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more
An initial question faced by a new hedge fund manager is whether or not registration with the U.S. Commodity Futures Trading Commission (CFTC) will be required. Limited Trading Exemption - CFTC Rule 4.13(a)(3), which...more
On March 5, the U.S. District Court for the Eastern District of Virginia dismissed a purported class action complaint in which plaintiffs alleged the defendant banks used “fictional” foreign exchange rates that deviated from...more
This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
Who may be interested: Exchange-Traded Funds - Quick Take: The staff of the SEC’s Division of Investment Management (Staff) issued a statement (Statement) providing its views on how ETFs holding foreign currency should...more
Introduction - The Trading Standards (Fair Trading) (Guernsey) Ordinance, 2023 (the "Trading Standards Ordinance") is due to come into force on 2 October 2023. From this date, businesses in Guernsey will be subject to...more
Who may be interested: Registered Investment Advisers. Quick Take: The SEC settled charges against a registered investment adviser alleging that the adviser failed to fully disclose to its clients foreign currency...more
Introduction - Class Plaintiffs in the case of In re Foreign Exchange Benchmark Rates AntiTrust Litigation alleged that Defendant banks conspired to fix prices in the foreign exchange (“FX”) market in violation of Sections 1...more
Holland & Knight's Venezuela Focus Team invites you to read our Venezuela Update, in which we discuss the latest news, trends and developments in Venezuela that impact the interests of businesses across all industry sectors. ...more
La Superintendencia Financiera de Colombia (SFC) expidió la Circular Externa No. 01 de 2023 con el objetivo de impartir instrucciones relativas a los derivados de crédito que pueden celebrar las entidades vigiladas....more
On Tuesday, the Third Circuit issued a decision that will substantially impact the sentences imposed for federal fraud offenses. In United States v. Banks, the Court rejected the so-called “intended loss” rule in the Federal...more
In MUR Shipping BV v RTI Ltd the English Court of Appeal has overturned by majority the judgment of the Commercial Court in MUR Shipping BV v RTI Ltd [2022] EWHC 467 (Comm) and provided fresh guidance on when alternative...more
As we approach the end of 2022, the international debt capital markets continue to remain challenging due to the successive shocks of the COVID-19 pandemic and ongoing supply chain disruptions, the war in Ukraine and...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 22, 2022 – August 26, 2022....more
In the 2022 Chambers and Partners Global Aviation Finance & Leasing Guide for the Cayman Islands, our aviation experts provide a comprehensive overview of the latest legal information regarding aircraft and engine purchase...more