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Foreign Investment Passive Foreign Investment Company

Hogan Lovells

The Pharma Industry and Investment Arbitration: What Chances for Foreign Investors?

Hogan Lovells on

The possibility for pharmaceutical companies to usefully resort to investment arbitration has been until recently shrouded in ambiguity. While the possibility to assume jurisdiction over cases concerning the registration of a...more

Freeman Law

The Section 965 Transition Tax And IRS Audits

Freeman Law on

Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more

Foodman CPAs & Advisors

Does investing in a PFIC make sense given FATCA reporting?

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more

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