FINCast Ep. 19 - The DPRK Sanctions Program
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
The Israeli legislature promulgated a new Angels Law at the end of July, with the goal of preserving Israel as an attractive hub for investments in high-tech companies by granting various tax incentives. (This temporary order...more
The adopted FSR Implementing Regulation contains important changes compared to the draft published in February 2023. The focus of the FSR filings for M&A deals and public tenders in the EU will be on companies' foreign...more
The second installment of a series of alerts focusing on practical issues relating to China’s new Foreign Investment Law. The two current models of foreign loans for Foreign Invested Enterprises reflect the Chinese...more
Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more
Article Highlights: - Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. - Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more