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Results: 1-10 of 21

U.S. Senate committee criticizes Apple, Inc. offshore tax practices relationship to “Swiss principal” structures

  • Kurtin PLLC
  • -
  • Ireland, Switzerland, USA
  • -
  • May 21 2013

On May 20, 2013, the U.S. Senate Permanent Subcommittee on Investigations published a memorandum criticizing the practices of consumer electronics

What matters: A review of 2011 and 2012

  • Kramer Levin Naftalis & Frankel LLP
  • -
  • USA
  • -
  • April 1 2013

As you know, the last two years have seen a somewhat improved, but by no means robust, business climate. At the same time, structural shifts in the

Are family funds a threat to private equity funds?

  • McDermott Will & Emery
  • -
  • United Kingdom, USA
  • -
  • November 28 2012

For most of the past two decades, private equity funds have had only two types of competition: strategic investors and each other

What the future holds for china’s VIE

  • Kaye Scholer LLP
  • -
  • China, USA
  • -
  • September 25 2012

Two recent and noteworthy events in the US and China cause one to ponder what the future holds for the variable interest entity (VIE), an ingenious creation which, for the past decade, has been widely used to attract eager foreign capital, because it seems to have overcome certain People's Republic of China (PRC) regulatory hurdles facing foreign investors while cleverly using US and international accounting standards that would inject financial life in to offshore companies even though such offshore companies do not own an equity stake in the Chinese operations

Recent developments for the fourth quarter 2011

  • Baker & McKenzie
  • -
  • Canada, China, Denmark, European Union, France, Germany, Ireland, Italy, Japan, Netherlands, Switzerland, United Kingdom, USA
  • -
  • March 15 2012

The end of the year and beginning of a new year is always a busy time for us, as it is for most of our clients

IRS issues new timeline for implementation of FATCA

  • Lowenstein Sandler PC
  • -
  • USA
  • -
  • August 18 2011

The IRS has issued a new timeline for implementing the onerous requirements imposed on foreign financial institutions (including foreign hedge funds and private equity funds) by the Foreign Account Tax Compliance Act (“FATCA”

Final FBAR regulations offer some relief for plan sponsors, but filing obligations remain

  • McDermott Will & Emery
  • -
  • USA
  • -
  • April 7 2011

The Treasury Department has issued final regulations concerning the FBAR filings

Dodd-Frank Act effect on non-US investment advisers

  • McDermott Will & Emery
  • -
  • USA
  • -
  • November 22 2010

The Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act), enacted on 21 July 2010 and effective with regard to investment advisory registration matters as of 21 July 2011, mandates significant changes to the regulation of offshore (from the United States) investment managers

New developments affect reporting obligations for U.S. interests in non-U.S. private investment funds

  • Schulte Roth & Zabel LLP
  • -
  • USA
  • -
  • March 23 2010

In late February, the Treasury Department (“Treasury”) issued Notice 2010-23 (“Relief Notice”) and Announcement 2010-16 (the “Announcement”), providing additional guidance relating to the filing of Reports of Foreign Bank and Financial Accounts (Form TD F 90-22.1) (“FBAR”) for all years through 2009

Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 3 2010

On February 26, 2010, the Treasury Department published long-awaited, revised proposed regulations clarifying which taxpayers will be required to file the Report of Foreign Bank and Financial Accounts, Form TD F 90-22

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