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19,824 results found


Shearman & Sterling LLP | USA | 19 Jun 2019

Final GILTI Regulations and Proposed Regulations on Subpart F Income and GILTI Bring Relief to Private Equity and Other Non-Corporate Investors

On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed


Sidley Austin LLP | USA | 19 Jun 2019

Proposed Regulations Provide Relief from GILTI and Subpart F Income Inclusions from CFCs for Private Equity Funds

On June 14, 2019, the U.S. Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) published proposed regulations (Proposed


Greenberg Traurig LLP | USA | 19 Jun 2019

Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S

Last year the IRS announced a new campaign to target “Withholding and International Individual Compliance” regarding Forms 1042 and 1042-S. Those who


Holland & Knight LLP | USA | 18 Jun 2019

Religious Institutions Update: June 2019

Government surveillance of individuals due to their religious identity is actionable under federal law. In Fazaga v. Federal Bureau of Investigation


Hunton Andrews Kurth LLP | USA | 18 Jun 2019

Private Letter Ruling Exempts Subsidiary REITs From Preferential Dividend Rule

In a recent private letter ruling, the Internal Revenue Service concluded that a subsidiary REIT of a "publicly offered REIT" is exempt from the


Fasken | Canada | 17 Jun 2019

Doing Business in Canada 2019: Franchising

Franchising is a business model pursuant to which a franchisor grants to a franchisee a licence to employ the franchisor's systems and methods of


Akerman LLP | USA | 14 Jun 2019

Tariff Threats Could Send Manufacturers Country-Hopping

Just when moving manufacturing from China to Mexico seemed like an option, the threat of U.S. tariffs on Mexico emerged. Despite a reported agreement


Frost Brown Todd LLC | USA | 14 Jun 2019

2019 Update - How to Deal with Section 1061's Three Year Holding Period Requirement for Carried Interests

Hedge fund, private equity and real estate professionals value the carried interest because it allows them to be compensated for their services at


White & Case LLP | United Kingdom | 14 Jun 2019

Through the wire - the SFO’s plan to obtain evidence using informants

An informant is sent into the midst of a criminal gang. He is wearing a concealed device, crudely taped to his chest. Law enforcement agents listen in


GrayRobinson PA | USA | 14 Jun 2019

The Golden Apple: Reporting on the latest discord from Capitol Hill

The House Financial Services Committee (HFSC) voted unanimously this week to approve a five-year reauthorization of the National Flood Insurance

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