News & Analysis as of

Offshore Companies Tax Liability

Falcon Rappaport & Berkman LLP

The Wyoming DUNA and the Future of DAO Legal Frameworks

Choosing the right legal structure for a decentralized autonomous organization (DAO) can make or break a web3 project before it deploys. From tax efficiency and governance mechanisms to liability protection and regulatory...more

Orrick, Herrington & Sutcliffe LLP

IRS Extends Date for Section 965 Liability Transfer Agreement

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

Orrick, Herrington & Sutcliffe LLP

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

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