Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
Insider Transaction Traps for the Unwary
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
5 Key Takeaways | Income Tax Jeopardy! A Potpourri of Hot Topics
REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
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
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
La Cour administrative d'appel de Paris se prononce sur la conformité à la CEDH de la différence de traitement des quotes-parts de frais et charges selon la localisation des filiales (CAA Paris, 11 février 2025, n°...more
This note only addresses subsidiaries of Nordic companies. Branch offices are rarely attractive for foreign companies because they result in direct exposure for the foreign company to liability in the U.S. and jurisdiction by...more
As businesses continue to expand their operations across borders—by engaging contractors, hiring employees, or initiating other revenue-generating activities overseas—understanding permanent establishment risks becomes...more
Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime de la charge de la preuve en matière de prix de transfert en présence d'avances consenties sans...more
Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more
Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more
I. Types of business entities - As a general rule, foreign equity is allowed to conduct and participate in business in the Philippines, through any of the following modes: 1. By investing in a domestic stock...more
I. General Overview - As of 2020, Mexico has a population of 126,014,024 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more
In 1964, the Mexican government introduced Maquiladoras as a strategy to attract foreign investment and increase industrialization on the Mexican border. Maquiladora’s process, produce, transform, or repair goods owned by...more
I. General Overview - As of 2015, Mexico has a population of 119,938,473 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more
On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more