Practice Mobile Menu Trigger Overview Experience Team Insights Subscribe to insights June 12, 2015 Articles & Books Amazon Branches Out Before clicking ‘buy now’, we are still advised that our internet purchases are ‘sold by Amazon EU S.a.r.L.’. Eagl... April 3, 2015 Client Update IRS Releases Final Regulations Under Section 162(m): Some Relief for Newly Public Companies On March 31, 2015, the Internal Revenue Service published final regulations under Section 162(m) of the Internal Revenue C... January 8, 2015 Client Update IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that... December 11, 2014 Client Update United Kingdom’s “Google Tax” – Government Unveils Draft Rules The UK Government published this week details of a new 25% “diverted profits” tax, which aims to counter cross-border ... September 23, 2014 Client Update Treasury Issues Long-Awaited Anti-Inversion Guidance The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that... September 10, 2014 Client Update Schumer Releases Draft Anti-Inversion Bill A draft of the bill that is being considered by Senator Schumer (D-NY) to reduce some of the economic incentives for corpo... May 21, 2014 Client Update Proposed Legislation Would Significantly Limit Inversion Transactions As expected, Senator Carl Levin and thirteen other Democratic Senators yesterday introduced a bill that would significantl... March 14, 2014 Articles & Books U.K. Companies Listing in the U.S. UK shares may be listed in the US for a variety of reasons, including as a result of an ‘inversion’ transaction. Histo... January 17, 2014 Client Update New Regulations Expand Reach Of Anti-Inversion Ownership Rules The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “... December 9, 2013 Client Update New Proposed and Final Regulations Address Withholding on “Dividend Equivalents” Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends f... Load More
June 12, 2015 Articles & Books Amazon Branches Out Before clicking ‘buy now’, we are still advised that our internet purchases are ‘sold by Amazon EU S.a.r.L.’. Eagl...
April 3, 2015 Client Update IRS Releases Final Regulations Under Section 162(m): Some Relief for Newly Public Companies On March 31, 2015, the Internal Revenue Service published final regulations under Section 162(m) of the Internal Revenue C...
January 8, 2015 Client Update IRS Internal Memorandum Concludes Offshore Fund Engaged in Lending and Underwriting Business in the United States On January 2, the Internal Revenue Service (the “IRS”) released a Chief Counsel Advice memorandum (the “CCA”) that...
December 11, 2014 Client Update United Kingdom’s “Google Tax” – Government Unveils Draft Rules The UK Government published this week details of a new 25% “diverted profits” tax, which aims to counter cross-border ...
September 23, 2014 Client Update Treasury Issues Long-Awaited Anti-Inversion Guidance The Treasury Department and the IRS yesterday released Notice 2014-52 (the “Notice”), which describes regulations that...
September 10, 2014 Client Update Schumer Releases Draft Anti-Inversion Bill A draft of the bill that is being considered by Senator Schumer (D-NY) to reduce some of the economic incentives for corpo...
May 21, 2014 Client Update Proposed Legislation Would Significantly Limit Inversion Transactions As expected, Senator Carl Levin and thirteen other Democratic Senators yesterday introduced a bill that would significantl...
March 14, 2014 Articles & Books U.K. Companies Listing in the U.S. UK shares may be listed in the US for a variety of reasons, including as a result of an ‘inversion’ transaction. Histo...
January 17, 2014 Client Update New Regulations Expand Reach Of Anti-Inversion Ownership Rules The Treasury Department and the Internal Revenue Service (the “IRS”) yesterday released temporary regulations (the “...
December 9, 2013 Client Update New Proposed and Final Regulations Address Withholding on “Dividend Equivalents” Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends f...