The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
AGG Talks: Cross-Border Business Podcast - Episode 26: U.S. Enforcement Trends Targeting Foreign Pharmaceutical and Medical Device Manufacturers
Scaling Success: Hanley Energy’s Journey From Ireland to the U.S.
Wiley's 10 Key Trade Developments: Outbound Investments and CFIUS Review
AGG Talks: Cross-Border Business - How Foreign Companies Can Protect Their IP and Brand in the U.S.
AGG Talks: Cross-Border Business - Navigating Business Etiquette and Intercultural Communications Around the Globe
AGG Talks: Cross-Border Business - Privacy & Cybersecurity Considerations for Non-U.S. Companies
AGG Talks: Cross-Border Business — Episode 6: Immigration Insights for Companies Expanding Into the U.S. - Part 2
AGG Talks: Cross-Border Business — Episode 6: Immigration Insights for Companies Expanding Into the U.S. - Part 1
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Economic Incentives for Foreign Companies Entering the U.S.
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
AGG Talks: U.S. Bankruptcy Basics for Foreign Investors
10 Things Lawyers Should Know About BVI Transactions
Nota Bene Episode 109: Asia Q1 Check In: China’s Emergence as the Number One World Economy and New Hegemonic Role in Asia with Paul Kim
The Evolution of Cross-Border Restructuring Processes
Nota Bene Episode 93: Navigating the New Global Cybersecurity Compliance Landscape with Scott Giordano
On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more
On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more
Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more
For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more
Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more
As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more
Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more
Canadian companies that award stock options to their employees, non‑employee directors and/or other service providers often inquire as to whether they should offer Incentive Stock Options (“ISOs”) to any such individuals who...more
Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more
The U.S. Supreme Court held the Mandatory Repatriation Tax (MRT) constitutional in Moore v. United States, No. 22-800, 602 U.S. _, decided June 20, 2024. The MRT requires some American shareholders of American-controlled...more
On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS)....more
With a significant mass of cases left to decide and only a few weeks to issue the opinions, the U.S. Supreme Court has reduced the backlog by four yesterday. None of them, however, resolves the future of Chevron deference or...more
The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more
On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more
In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more
On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more
Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more
The Supreme Court recently granted certiorari in the case Moore v. United States to review a Ninth Circuit Court of Appeals decision affirming application of the “transition tax” under Section 965, enacted as part of the Tax...more
1. OFAC Imposes Sanctions on Russian Elites Who Were Board Members of Alpha Group- On Aug. 11, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Russian individuals, Petr...more
It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at...more
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed to file Forms 5471 reporting his interest...more
The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more