Since Congress first introduced the Corporate Transparency Act (“CTA”) and the beneficial ownership information reporting framework in January 2021, much of the focus has been on the specific reporting requirements that now...more
The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more
On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more
On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...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
Beginning on January 1, 2024, certain reporting companies are now required to comply with the disclosure requirements of the Corporate Transparency Act (CTA). This law aims to enhance transparency in corporate ownership,...more
Effective January 1, 2024, companies must disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN) within the United States Department of Treasury. The reporting requirement is part of the U.S....more
This advisory provides a general summary of the Corporate Transparency Act and its requirements and is not intended to, and does not, provide legal, compliance or other advice to any individual or entity....more
As we approach the end of 2023, nearly all privately owned businesses operating in the United States must prepare for the implementation of the Corporate Transparency Act (“CTA”), a federal law taking effect on January 1,...more
The Financial Crimes Enforcement Network (“FinCEN”) has published a new Small Entity Compliance Guide (“Guide”) for compliance with the Beneficial Ownership Information Reporting Rule (“Reporting Rule”), 31 CFR 1010.380. The...more
In Mallory v. Norfolk Southern Railway Co., Robert Mallory (a Virginia resident) sued his former employer, Norfolk Southern (a Virginia-based railroad), over his alleged exposure to toxic chemicals while working for Norfolk...more
Let’s say that your company is incorporated in Michigan, headquartered in Michigan, and does business there and in a dozen other states. One of your customers in Texas claims the products it purchased from you and that you...more
The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more
The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more
As previously reported, on September 30, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued the final rule to implement the beneficial ownership reporting requirements of the Corporate...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule on Sept. 29, 2022, implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more
On September 29, 2022, FinCEN issued a final rule requiring most corporations, limited liability companies and other entities created in or registered to do business in the United States to report information regarding their...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock (the Buyback...more
The US Securities and Exchange Commission (SEC) proposed new climate change disclosure rules on March 21, 2022. The proposed rules (Release Nos. 33-11042; 34-99478) draw heavily on the “four pillar” disclosure framework...more
Foreign investment into China is governed by the new Chinese Foreign Investment Law ("Foreign Investment Law "), as well as its Implementing Rules ("Implementing Rules"), which took effect on January 1, 2020. A key feature of...more
On December 8, 2021, the U.S. Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) implementing Section 6403 of the Corporate Transparency Act (CTA), which gives the public until...more
Pending legislation would require public companies in California to have at least one director from an underrepresented community by the end of 2021 and would mark the second instance of California seeking to force the...more