5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
Foreign Correspondent Podcast | The America First Investment Policy and What it Means for Investors
Podcast - A Comparative Guide to Obtaining an FCL: DCSA vs. the Intelligence Community
Podcast - The "I" in FOCI and AI: Innovation, Intelligence, Influence
Podcast - What Are Joint Ventures and When Should They Get Cleared?
AGG Talks: Cross-Border Business Podcast - Episode 27: U.S. Healthcare Reimbursement Guidance for Foreign Life Sciences Companies
2025 Perspectives in Private Equity: Cross-border Investment Review and New Restrictions
2025 Perspectives in Private Equity: Public Policy
AGG Talks: Cross-Border Business Podcast - Episode 25: Venture Capital Trends and Fundraising Strategies for Foreign Startups Expanding to the U.S.
Foreign Correspondent: An FDI Podcast | Mapping the National Security Landscape for Investors
AGG Talks: Cross-Border Business Podcast - Episode 23: Shaping Georgia’s Energy Landscape: Insights From Commissioner Tim Echols
AGG Talks: Cross-Border Business Podcast - Episode 22: What Global Companies Need to Know About Navigating FDA Regulations and U.S. Market Entry
Taking the Pulse, A Health Care and Life Sciences Video Podcast | Episode 217: Japanese Investment in North Carolina’s Life Sciences Industry with David Robinson of Maynard Nexsen
Private M&A 2024: Key Trends and Forecasts
Everyone Come to Play: Exploring FOCI Mitigation Instruments
AGG Talks: Cross-Border Business Podcast - Episode 19: The Rise of Korean Investment in the Southeast U.S.
Episode 337 -- Nicolas Garcia, GC at Orica, on Compliance Trends and Challenges in Latin America
Understanding FOCI Mitigation
Scaling Success: Hanley Energy’s Journey From Ireland to the U.S.
Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....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
If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...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 secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...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 December 29, 2022 the IRS and the Treasury Department issued a notice of proposed rulemaking (REG-100442-22) (the “Proposed Regulations”) that, among other things, affects the determination when Real Estate Investment...more
The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more
Takeaways - The technical architecture of various cryptocurrencies makes it difficult to bring them within existing tax rules, even those designed to deal more generally with the digital marketplace. The U.S., U.K. and...more
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more
While there is an anticipation of greater predictability under a President Joe Biden, which is critically important to the commercial real estate industry, expected and potential changes in trade, taxation, housing and health...more
On 9/14/20, the IRS announced 4 New Compliance Campaigns . One Campaign addresses FIRPTA (Foreign Investment in Real Property Tax Act of 1980) Reporting Compliance for Non-Resident Aliens (NRAs). FIRPTA authorized the United...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
• The broader application of Section 871(m) has been delayed further until January 1, 2021 and, as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S. withholding...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more
In response to perceived abuses in taxpayers’ use of swaps and other derivative transactions (e.g., options, futures or forwards) to avoid withholding tax on U.S. source dividends, Congress added Section 871(m) to the...more
On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more
The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more