Episode 319 -- Deep Dive into SCG Plastics' $20 Million Settlement with OFAC for Violations of the Iran Sanctions Program
Jones Day Talks: Italy Embraces Foreign investment but Maintains Oversight
Jones Day Talks: Doing Deals Down Under: Australia's Foreign Direct Investment Regime
FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
In October of this year, the Israel Securities Authority published a memorandum of law aimed at regulating broker-dealer activities in Israel. Public comments will be accepted until 21/11/24. At issue is an initiative that...more
Be wary: The US Department of the Treasury’s proposed disregarded payment loss (DPL) regulations lay surprising new traps for multinational taxpayers – and those ensnared are unlikely to see what’s coming. Under the...more
The Inflation Reduction Act of 2022 brought about modifications to the clean vehicle tax credit available under Section 30D of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Clean Vehicle...more
On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more
The U.S. Department of the Treasury and IRS on Dec. 1, 2023, released proposed rules under Section 30D of the Internal Revenue Code, the Clean Vehicle Tax Credit, as they relate to the definition of "foreign entity of...more
Filing fees under the Hart-Scott-Rodino (HSR) Act have not been altered for 20 years, but that is about to change, and dramatically in 2023. President Biden is expected to sign into law the Consolidated Appropriations Act,...more
The European Commission has published a far-reaching proposal for a regulation to tackle foreign subsidies affecting the EU internal market. This proposal appears as a game changer for foreign direct investment. If adopted,...more
Following the ground-breaking People's Republic of China (PRC) Foreign Investment Law (FIL) which unifies and replaces the main existing rules governing foreign invested enterprises (FIEs) and their activities, namely the...more
The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more
In April, the IRS issued proposed regulations interpreting deemed distributions under Section 305(c). Specifically, the proposed regulations would clarify the amount and timing of deemed distributions that result from an...more
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more
The principal effect of the rules would be to turn virtually any contribution of appreciated property by a US person to a section 721(c) partnership into a taxable gain recognition event. On August 6, the US Treasury...more