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Husch Blackwell LLP

Recent Developments from the OBBBA and EO 14315: Rush to Begin Construction and Pricing Uncertainty

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As we have discussed in recent articles and as has been well publicized, two recent actions out of Washington are significantly impacting the renewable energy industry. The recently enacted One, Big, Beautiful Bill Act...more

Walkers

Overview of the Cayman Islands Economic Substance requirements

Walkers on

Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more

Seyfarth Shaw LLP

7 Key Changes to the Qualified Opportunity Zone Incentive Under the One Big Beautiful Bill Act

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On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more

Sheppard Mullin Richter & Hampton LLP

Understanding the Federal Reconciliation Bill’s Implications for MCO Tax Structure

New York’s Medicaid financing strategy—particularly its use of a managed care organization (MCO) tax—has come under renewed federal scrutiny amid recent legislative proposals and regulatory developments. The federal...more

DLA Piper

Italian Tax Authority Provides Guidance on VAT Treatment of Personnel Secondment Arrangements

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Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more

Walkers

Thinking ahead: Key considerations for winding up Guernsey investment funds

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The process of winding up a Guernsey fund involves several important considerations that boards, fund managers, investment advisers and administrators must navigate carefully. This article explores six aspects which we...more

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Legal Issues Facing Owners and Operators of Data Centers in Japan

As experienced investors in Japanese real estate know, the Tokutei Mokuteki Kaisha (TMK) is the Japanese entity used by most investors to acquire and hold large real estate assets due to its favorable tax treatment. It is...more

Conyers

Cayman STAR Trusts: A Powerful Structure for Employee Benefit Trusts and Master Insurance Policies

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The Cayman Islands is a premier jurisdiction for innovative trust structures, and its STAR trusts have gained prominence for their flexibility and utility in corporate settings. STAR Trusts are a form of trust that is unique...more

IR Global

New Opportunities in Global Mobility

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What are the key considerations for businesses and individuals navigating cross-border mobility in your jurisdiction?...more

Cadwalader, Wickersham & Taft LLP

For 2025, Crypto Taxpayers Can Get Their Ducks in a Row; But Senator Cruz Says “Nyet” to DeFi Regs

Last year, the Treasury and IRS released two sets of final crypto reporting regulations. The first set, in July, imposed rules for custodial brokers. The second set, in December, imposed rules for DeFi. This piece provides...more

Mayer Brown

The Finalized Disclosure Requirements for Partnership Basis-Shifting Transactions: Slightly Less Onerous, but Still Premature

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On January 14, 2025, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) addressing reporting obligations with respect to certain...more

Mayer Brown

Déductibilité des intérêts portant sur les obligations convertibles : validation de l'utilisation du logiciel Standard et Poor's...

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Par un arrêt du 28 janvier 2025, le Tribunal administratif de Cergy Pontoise (n°2100034) approuve l'utilisation du logiciel Standard et Poor's Capital IQ pour justifier le taux d'intérêt d'obligations convertibles....more

Foley & Lardner LLP

Mandatory Roth Catch-up: More than Meets the Eye

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In January, the Department of the Treasury (“Treasury”) and Internal Revenue Service (IRS) issued proposed regulations on the catch-up contribution provisions under the SECURE 2.0 Act of 2022 (“SECURE 2.0”). While the...more

Husch Blackwell LLP

Reflections on First Minnesota Adult Use Cannabis General Licensing Window

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Like many others, we were caught up in filing a slew of Minnesota adult use cannabis applications for our clients by March 14 (which, if you were paying attention, that deadline was extended to March 15 by midnight because of...more

Eversheds Sutherland (US) LLP

San Francisco’s proposed regulation imitates California’s proposed regulation

In November 2024, voters approved Proposition M which provided for an overhaul of San Francisco’s gross receipts tax. Proposition M changed the allocation and apportionment rules for most industries, generally requiring that...more

McDermott Will & Emery

Unclaimed Property Laws and the Health Industry: Square Peg, Round Hole

McDermott Will & Emery on

Likely due to the tremendous number of healthcare mergers, acquisitions, and private equity deals that have been taking place, the industry has recently been the target of multistate unclaimed property audits. This increased...more

McDermott Will & Emery

IRS Roundup February 17 – March 14, 2025

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Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Standard Formula: Encyclopaedia of Prudential Solvency – Chapter 2: The Bermuda Prudential Solvency Regime

This chapter discusses the Bermudian prudential solvency regime. Bermuda rose to prominence in the insurance and reinsurance industries in the late 1960s and early 1970s, largely due to its pioneering work in the...more

Goodwin

Was Your SIF Set Up Before 2016? Consider a RAIF Conversion While Evaluating the Benefits of Maintaining a SIF

Goodwin on

The Specialised Investment Fund (SIF) regime was established in Luxembourg by the Law of 13 February 2007 (the “SIF Law”). The SIF regime’s purpose was to offer great flexibility on investment scope while structuring and...more

Walkers

Moving to the Channel Islands: A guide for asset managers

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Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more

Mayer Brown

STF Establishes Non-Incidence of ISS on Commissioned Manufacturing Activities

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The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more

McDermott Will & Emery

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Emery on

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Cadwalader, Wickersham & Taft LLP

The New UK Reserved Investor Fund: RIFs and QAHCs Create an Ambitious UK Structuring Toolkit

Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more

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