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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

Aug 02, 2018

What the Altera Case Could Mean for Multinational Companies

The IRS scored a major victory in the recent transfer pricing case, Altera Corp. & Subsidiaries v. Commissioner, No. 16-70496 (9th Cir. 2018).  The issue before the Ninth Circuit was the validity of transfer pricing regulations that require related companies to allocate expenses that unrelated parties do not share when dealing at arm’s length.» Read More

Jul 13, 2018

Product Liability – Consumer Products – Italy: The Manufacturer is Responsible if the Tissue Contains Nickel and the Consumer is Not Adequately Informed

The below post is written by guest author Elena Bassan, an attorney with the Italian law firm Studio Bassan.

 Today, we comment on a ruling of the Supreme Court of Cassazione (no. 3692 of 15 February 2018) concerning a product reported to be allegedly defective due to its content of heavy metals (nickel).» Read More

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