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
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
The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...more
Changes to the beneficial ownership regime took effect on 31 July 2024 and enforcement relating to the new requirements is suspended until early 2025. Many entities that previously had few or no obligations will have to...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
What is the CTA? The CTA was passed by Congress on January 1, 2021 as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to prevent illicit activity, including the use of shell and front companies to...more
Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more
Effective January 1, 2024, companies must disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) within the United States Department of Treasury. The reporting requirement is part of the U.S....more
The Financial Crimes Enforcement Network (“FinCEN”) has published a new Small Entity Compliance Guide (“Guide”) for compliance with the Beneficial Ownership Information Reporting Rule (“Reporting Rule”), 31 CFR 1010.380. The...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
On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more
The Final Rule issued under the Corporate Transparency Act (CTA) is, as forecast, a sweeping and significant update to the U.S. anti-money laundering laws, estimated to affect over 32 million entities by requiring new reports...more
• ECRA became law on August 13, 2018. It is the permanent statutory authority for the EAR, which is administered by the U.S. Department of Commerce’s BIS. The new law codifies long-standing BIS policies and does not require...more
On March 14, 2018, the House Committee on Foreign Affairs held a hearing titled “Modernizing Export Controls: Protecting Cutting Edge Technology and U.S. National Security” to examine the proposed Export Control Reform Act...more
• The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign Corrupt Practices Act (FCPA) will, with slight revisions, be made permanent. •...more
We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more
Early in July 2014, the Russian Federal Act on Data Protection was amended to require that personal data of Russian citizens be first processed and stored on servers located within the territory of Russia. Initially, the...more
There are many branches, agencies, and subsidiaries of foreign banks licensed to conduct banking business here in New York. These foreign-bank offices are often the targets of civil discovery requests seeking production of...more
As I discussed in this earlier post, “transacting intrastate business” is not the same as “doing business” in this state. Foreign corporations and limited liability companies must register with the Secretary of State if they...more