News & Analysis as of

Multinationals Affiliates

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Latham & Watkins LLP

GDPR Fines to Be Determined by Reference to Global Turnover of Corporate Group

Latham & Watkins LLP on

The CJEU has decided that the maximum thresholds for GDPR fines should be calculated using the global turnover of the broader corporate group, not solely the infringing entity....more

Barnea Jaffa Lande & Co.

Warning, Border Ahead? Expanding Israeli Courts' Jurisdiction over Foreign Defendants

In early June 2021, the Tel Aviv-Yafo District Court handed down an important precedential ruling. The ruling expands the identity of an authorized agent, i.e., the entity to whom a statement of claim may be served and that...more

Eversheds Sutherland (US) LLP

Tough Medicine: Litigation lessons from Medtronic

Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

Foley & Lardner LLP on

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

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