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It is not uncommon for a corporation to have net operating losses ("NOLs") that may be carried forward from year-to-year, and may be used to offset the corporation’s taxable income in future years. A corporation’s ability to...more
The Bermuda Registrar of Companies (RoC) has advised that it will be launching the first phase of its new company registry system on 7 June 2021. Economic Substance Declarations that have been started must be finished and...more
What kinds of cloud computing transactions take place in your jurisdiction? As a G7 economy with mature IT and related services markets, the UK is one of the most important global markets for cloud computing. According to...more
Whilst political uncertainty may have businesses’ attention fixed, the Hogan Lovells Global Survey on Digital Regulation: ‘A Turning Point for Tech’ suggests that tech companies should be looking elsewhere. During yesterday’s...more
‘Corporate reorganisation’ is something of an umbrella term, and is used in many different contexts to mean a multitude of different things. At one extreme, a reorganisation may refer to ‘paper’ changes to a corporate group’s...more
A limited liability company (an “LLC”) is a business structure created by state statute, but it is not a distinct business entity for tax purposes (like a partnership or a corporation). Instead, businesses structured as LLCs...more
The Internal Revenue Service and the Treasury Department released an updated Priority Guidance Plan outlining the regulatory projects that have become necessary in light of the passage of the 2017 Tax Cuts and Jobs Act (the...more
Canadian public merger and acquisition transactions in 2016 (in-bound and out-bound) comprised over C$400 billion in value with at least one-third of the transactions in Canada being fueled by foreign buyers. The second...more