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Ogier | British Virgin Islands | 6 Jan 2022

Snapshot: can you assign a chose in action in BVI law?

A "chose in action" means a property right or the right to possession of something that can only be obtained or enforced through legal action. It is an "intangible" – for example, a receivable, a right to recover money or a debt. BVI statute does not currently provide for the legal assignment of a chose in action governed by BVI law. As a consequence, any assignment of a chose in action will......
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Freshfields Bruckhaus Deringer | United Kingdom | 26 Nov 2018

Offshore IP owners beware! More rules to tax UK-generated value could result in multiple tax charges

HMRC is apparently not satisfied with the range of tools now at its disposal to impose UK tax on the value generated from the UK using intangible…
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Blaney McMurtry LLP | Canada, USA | 26 Nov 2018

Posco Daewoo: U.S. District Court applies Ownership Condition in rejecting Creditor’s “Reverse” Social Engineering Fraud Claim under its own Crime Policy

On November 19, 2018, the U.S. District Court for the District of New Jersey released its decision in Posco Daewoo America Corp. v. Allnex USA, Inc…
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Steptoe & Johnson LLP | OECD, USA | 19 Nov 2018

IRS Issues Final Regulations on Cost Allocations

IRS Issues Final Regulations on Cost Allocations: Today, the Treasury Department and the IRS published final regulations on allocating costs to…
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Nelson Mullins Riley & Scarborough LLP | USA | 14 Sep 2018

Proposed Regulations Provide Guidance on 20% Deduction for Qualified Business Income

The Department of Treasury issued in August proposed regulations (REG-107892-18) (the "Proposed Regulations") under Section 199A of the Internal…
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Steptoe & Johnson LLP | USA | 31 Jul 2018

FINRA Encourages Firms to Report Involvement in Activities Related to Digital Assets

In a Regulatory Notice published July 6, 2018, the Financial Industry Regulatory Authority (FINRA) encourages its members to promptly notify FINRA if…
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Fenwick & West LLP | USA | 22 Jun 2018

New Field Attorney Advice Explores the Intersection of § 1253 with the Anti-Churning Rules of § 197

A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a…
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Katten Muchin Rosenman LLP | USA | 15 Jun 2018

Investment Bank Ex-Employee’s Conviction Upheld for Theft of High-Frequency Trading Algorithmic Code

New York’s highest court - the NY Court of Appeals - upheld the conviction of Sergey Aleynikov, a former computer programmer for Goldman Sachs & C…
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Greenberg Traurig LLP | USA | 28 Mar 2018

Token Issuers and Purchasers, Beware: The IRS May Tax Each Time Tokens are Used

Many blockchain companies are using a largely unregulated means of raising funds, commonly known as an initial coin offering (ICO). An ICO consists…
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Nexsen Pruet | USA | 15 Feb 2018

Protecting the Collected Knowhow of an Assembled and Trained Workforce

The notion of protecting knowhow is strange to those who think of intellectual property as comprising patents, trademarks, and copyrights. Knowhow is…
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