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The Cayman Islands is the most common non-US jurisdiction for listed entities - Entities established in 47 different jurisdictions are currently listed on the NYSE and Nasdaq. Of these different jurisdictions, outside of...more
We are seeing an increasing number of enquiries from lenders and their advisors in respect of the practicalities of enforcement by receivers of English security granted by overseas entities. Real estate property transactions...more
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
As of February 10, 2024, new rules will apply to foreign entities that want to offer securities brokerage services via their marketers in Israel. The Israel Securities Authority promulgated these rules in December 2023, as...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020... September 21, 2020: The IRS released Announcement...more
The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC) data reporting system. Form SHC is the mandatory five-year...more
Form Deadline Is March 3, 2017 - Introduction - The U.S. Department of the Treasury recently released a revised Form SHC (with corresponding instructions), which is part of the Treasury International Capital (TIC)...more