In recognition of the COVID-19 global pandemic, the Registrar of Corporations for nonresident domestic corporations formed in the Republic of the Marshall Islands has adopted new regulations addressing the conduct of...more
On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more
As in the 9 percent "amusement tax" that the city of Chicago recently extended to online streaming services like Netflix and Amazon Prime, triggering a series of lawsuits alleging that the newly expanded tax was illegally...more
Recent congressional action regarding Inverted Domestic Corporations (IDC) may lead to further limitations on the ability of IDCs to contract with the federal government. Starting with the 2002 legislation that established...more
GOVERNMENT CONTRACTS - DoD, GSA, and NASA Issue Proposed Rule to Amend FAR Prohibition on Contracting With Inverted Domestic Corporations – Representations and Notifications - ...more
The increasing use of corporate inversions, whereby a company via merger achieves 20 percent or more new ownership, claims non-U.S. residence, and is then permitted to adopt that country’s lower corporate tax structure and...more
On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will...more
On January 29, 2013, a final rule was issued prohibiting the award of contracts to inverted domestic corporations. The final rule requires an offeror to represent that it is not an inverted domestic corporation and creates...more