Episode 319 -- Deep Dive into SCG Plastics' $20 Million Settlement with OFAC for Violations of the Iran Sanctions Program
Jones Day Talks: Italy Embraces Foreign investment but Maintains Oversight
Jones Day Talks: Doing Deals Down Under: Australia's Foreign Direct Investment Regime
FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more
On May 22, the U.S. House of Representatives passed an amended version of H.R. 1—the One Big Beautiful Bill Act (the Bill) — by a vote of 215-214. The House-passed version of the bill, slated to be considered by the Senate...more
As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more
Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups....more
On August 22, 2024, Germany’s Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation, particularly for Luxembourg-based funds investing in Germany....more
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more
One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more
The IRS recently issued general legal guidance illustrating the application of the often misunderstood relevance rules for foreign entities in various settings....more
On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”. The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more
Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges. Join members...more
On 1 January 2018, the amendments to the CIT Act entered into force. As pointed out in the explanatory memorandum to the bill, the principal objective of the introduced changes is the closer monitoring of the Corporate Income...more
On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more
One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more