Law Firm ILN-telligence Podcast | Episode 76: Henrique Lopes, KLA Advogados | Brazil
International Litigation and Transactions in the Face of GDPR – A Panel Preview
The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more
On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more
The U.S. Bureau of Economic Analysis (BEA) has announced it is once again time for the BEA’s BE-10 Benchmark Survey of U.S. Direct Investment Abroad. The BEA is an agency of the United States Department of Commerce and...more
On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer to allocate a portion...more
Companies doing business in the Middle East take note: The Treasury Department recently published its quarterly list of countries that currently require participation or cooperation with an international boycott, such as the...more
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more
I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more
On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more