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Proposed Regulations for Foreign-Owned US LLCs Move Toward Increased Financial Transparency
  • Steptoe & Johnson LLP
  • USA
  • May 23 2016

On May 5, the US Department of the Treasury (Treasury) announced proposed regulations to increase the reporting and record maintenance requirements


US Treasury Announces Measures to Enhance Anti-Money Laundering, Bank Secrecy Act Compliance and Tax Evasion Rule Compliance
  • Shearman & Sterling LLP
  • USA
  • May 18 2016

On May 6, 2016, the US Treasury Department put forth several measures to combat money laundering, corruption and tax evasion, in the wake of the


2016 Summary of New Maine Laws: State of Maine 127th Legislature, 2nd Regular Session
  • Pierce Atwood LLP
  • USA
  • May 16 2016

The new laws highlighted in this summary are those most relevant to our clients and does not include all laws enacted this past session. This summary


Proposed Regulations Would Treat Certain Related-Party Debt Instruments Issued on or After April 4, 2016 as Stock for Federal Tax Purposes
  • Vorys, Sater, Seymour and Pease LLP
  • USA
  • May 3 2016

The IRS recently issued proposed regulations that, if finalized, would treat debt instruments between related persons as stock under certain


Doing Business in North America (Volume 1 - United States)
  • Miller Canfield PLC
  • USA
  • April 23 2016

In choosing to conduct business in the United States, businesses based in other countries should keep in mind that business entities are formed under


“Bad Boy Guarantee” of Non-Recourse Partnership Debt
  • Sullivan & Cromwell LLP
  • USA
  • April 18 2016

On April 15, 2016, the IRS released a generic legal Advice Memorandum (the “GLAM”) providing an important and helpful clarification of the treatment


Internal Revenue Service Takes a Look at “Bad Boy” Guarantees
  • Dickinson Wright PLLC
  • USA
  • April 18 2016

It is common for LLCs operating (and taxed) as real estate partnerships to obtain nonrecourse financing secured only by the real estate owned by the


Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
  • Caplin & Drysdale, Chartered
  • USA
  • April 5 2016

In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require


Tax Treatment of “Bad Boy Guarantees” Challenged by Recent IRS Memorandum
  • Morrison & Foerster LLP
  • USA
  • March 22 2016

A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that


The State AG Report Weekly Update February 4, 2016
  • Cozen O'Connor
  • USA
  • February 4 2016

Washington Attorney General Sues State Labor Council for Alleged Campaign Finance Violations. Washington AG Bob Ferguson filed a complaint against