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Foreign Entities New Guidance

Paul Hastings LLP

IRS and Treasury Tighten Beginning-of-Construction Rules for Wind and Solar

Paul Hastings LLP on

On Aug. 15, the U.S. Treasury Department and the Internal Revenue Service (IRS) released IRS Notice 2025-42, narrowing the rules for what qualifies as “beginning of construction” (BOC) under the One Big Beautiful Bill Act...more

Cadwalader, Wickersham & Taft LLP

American Cousins: HMRC Revisits Anson

On 12 December 2023, H.M. Revenue & Customs (“HMRC”) updated its guidance on foreign entity classification and, specifically, HMRC’s treatment of profits of, and distributions by, United States-established limited liability...more

Latham & Watkins LLP

English Court Provides Guidance for Commencing Proceedings On Foreign Defendants

Latham & Watkins LLP on

The English Court has set aside permission to bring proceedings against foreign defendants based on non-disclosures and subsequent conduct. The recent decision in Punjab National Bank (International) Limited v Ravi...more

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