Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Almost a year after President Biden signed an Executive Order to establish a U.S. outbound investment regime, the U.S. Department of the Treasury has published a Notice of Proposed Rulemaking (“NPRM”) on U.S. outbound...more
Captive insurance companies are likely exempt from filing a Beneficial Ownership Information (BOI) Report under the insurance company exemption to the Corporate Transparency Act (CTA). Likewise, companies that are owned by...more
1. OFAC Imposes Sanctions on Russian Elites Who Were Board Members of Alpha Group- On Aug. 11, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Russian individuals, Petr...more
Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
The judgment provides useful jurisdictional clarifications for deals involving joint ventures (JVs) acting as an acquirer. The General Court (GC) confirms that when the true players behind the transaction are the parent...more
The Federal Trade Commission has issued an administrative complaint challenging Axon Enterprise, Inc.’s consummated acquisition of its body-worn camera systems competitor VieVu, LLC from parent company from Safariland....more
Google announced late Tuesday that co-founders Larry Page and Sergey Brin are “stepping down from executive roles at Google’s parent company, Alphabet.” Google CEO Sundar Pichai will now helm both operations, while Page and...more
Could private equity funds be liable for human rights breaches by a portfolio company? A recent decision by the UK Supreme Court increases the likelihood of this outcome. This blog looks at the judgment in Vedanta Resources...more
Mounting pressure on businesses to gain clarity on their social and environmental footprint will challenge corporate operations in 2019. New risks are present but there are also opportunities for companies willing actively to...more
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more
Following the UK’s historic vote to leave the EU, numerous questions have arisen, including whether the UK will really leave the EU and whether Scotland and Northern Ireland (both of which voted to remain in the EU) will have...more
The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more