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Tax Planning Subsidiaries

Cadwalader, Wickersham & Taft LLP

Nordcurrent: Interpreting Anti-Abuse Rules

On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more

Partridge Snow & Hahn LLP

Key Considerations for Creating a For-Profit Subsidiary of a Public Charity

OpenAI, an artificial intelligence research nonprofit, has recently garnered media attention for considering a restructuring strategy involving the formation of a taxable subsidiary....more

Venable LLP

From One State to Another: Changing a Nonprofit's State of Incorporation

Venable LLP on

Nonprofits periodically ask how they can change their legal domicile or state of incorporation from one state to another. For some, an evolution in the location of physical or virtual headquarters, the type and nature of...more

Mintz - Employment Viewpoints

Checklist for Foreign Companies Expanding into the US

You’re a foreign company looking to set up shop in the United States. You have weighed the pros and cons of expanding your business into the United States, c..onfirmed the compatibility of any products or services you offer...more

Barnea Jaffa Lande & Co.

New Israeli Court Ruling on Artificial Transactions

A recent court ruling in the Shalam Packaging Products Group case addressed claims made by the Netanya tax assessor. The assessor argued the group executed a restructuring solely to reduce its tax liabilities by offsetting...more

Cadwalader, Wickersham & Taft LLP

Breaking Up: Case Study on GE’s Proposed Spin-Offs

The Cadwalader Tax team has prepared a case study summarizing General Electric’s recently announced plans to split into three publicly traded companies through sequenced tax-free spin-off transactions. ...more

Williams Mullen

ESOP Essentials: Can My Company Offer An ESOP? Selected Tax Guidance on Choice of Entity, Business Structure and ESOPs

Williams Mullen on

An employee stock ownership plan (ESOP) is a type of tax-qualified retirement plan. ESOPs are designed to invest primarily in qualifying employer securities, as defined in applicable tax rules....more

Cadwalader, Wickersham & Taft LLP

RMTs Roll On: Case Study on AT&T’s RMT Deal with Discovery

Earlier this week, AT&T and Discovery announced the proposed $43 billion merger of WarnerMedia with Discovery through a Reverse Morris Trust transaction, in what is the largest deal of 2021 thus far. Read the Cadwalader Tax...more

Seyfarth Shaw LLP

Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations

Seyfarth Shaw LLP on

Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more

Alston & Bird

Foreign Books and Records

Alston & Bird on

Our Federal Tax Group explores how a foreign person’s books can become relevant for U.S. tax purposes even when it has no contact with the U.S. tax system....more

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