Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Bill on Bankruptcy: Big Time Lawyers Pricing Themselves Out
Draft law “On Activities of Foreign Companies in the Internet in the Territory of the Russian Federation,” introduced to the State Duma, a lower chamber of the Russian parliament, on May 21, 2021, aims to extend Russian...more
Cabinet resolution number 31 of 2019 concerning economic substance requirements was recently published on the Ministry of Finance website. The issuance of this resolution requires companies operating a ‘relevant activity’ in...more
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-16 (the Notice) providing additional guidance regarding the transition tax in section 965 of the Internal Revenue Code of...more
A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more
There is no love lost between the U.S. Treasury and U.S. companies seeking offshore tax homes. Absent congressional action to stem the inversion tide, the Treasury and IRS are left to flex their regulatory and administrative...more
In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more
The Stop Tax Haven Abuse Act and the International Tax Competitiveness Act of 2013 are two parts of a package of three bills introduced in the U.S. House of Representatives on April 15 by Rep. Lloyd Doggett. A significant...more