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International Business Law Blog

Things you need to know about international business and tax law.

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Dec 28, 2018

Deadline for Reporting Final Beneficiary to Brazilian Federal Revenue Ends on December 31

The below post is authored by our friends Ana Carolina Veloso Ferreira and Ana Paula Terra Caldeira at Azevedo Sette Advogados.

Are you a United States entity with significant capital or controlling interest in a Brazilian subsidiary? Year-end reporting requirements are fast approaching.» Read More

Dec 19, 2018

Committee on Foreign Investments in the US (CFIUS) is Fired Up

CFIUS has been around since 1975, when President Gerald Ford, by Executive Order, created the interagency committee to review national security implications of investments by foreigners in U.S. businesses.  For most of the time since its creation, the power of CFIUS was primarily reactive, infrequently addressing pending transactions; even then, CFIUS’s jurisdiction covered only transactions where a foreign person acquired control of a US business.» Read More

Oct 18, 2018

Establishing Bank or Financial Accounts in the US – Consider the Impact of New FinCEN Rules on Beneficiaries

The Customer Due Diligence (“CDD”) regulations issued by the Financial Crimes Enforcement Network (FinCEN) became effective on May 11, 2018.  The regulations enacted under the Bank Secrecy Act clarify customer due diligence requirements for banks and other financial institutions.  These rules are part of an international effort to combat the use of legal entities such as corporations, limited liability companies, and partnerships from financers of terrorism, money launderers, tax evaders, and other financial criminals.» Read More

Aug 21, 2018

Manafort’s Trial Reminds Us of Looming OVDP Deadline

With the trial of Paul Manafort in the news, I’ve been thinking of the numerous conversations I have had with clients about properly disclosing foreign financial assets. Among other counts, Paul Manafort is charged with concealing foreign payments and offshore accounts from the U.S.» Read More

Aug 08, 2018

Surprising Altera Withdrawal for Multinational Companies

In a surprising twist of events, the Ninth Circuit Court of Appeals withdrew their recent transfer pricing decision against Altera Corp.1  The Ninth Circuit previously upheld Treasury regulations regarding the criteria for a cost-sharing arrangement to be considered qualified and thus avoid an IRS adjustment. » Read More

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