Ancillary agreements play a crucial role in acquisition transactions, complementing and supporting the primary acquisition agreement. Common ancillary agreements include employment agreements, non-competition...
Countering the financing of terrorism remains a top priority of the U.S. government. Financial institutions are obliged to identify terrorists and terrorist organizations included on sanctions lists and...
Power purchase agreements operate as the main source of guaranteed revenue for both traditional and renewable power generation facilities. Because power generation facilities are often financed with non...
Liquidating distributions are the distributions through which a partnership or limited liability company (LLC) terminates a partner's or a member's interest in the entity. Like current distributions...
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently issued a nationwide reporting rule effective December 1, 2025. This new rule mandates certain reporting requirements...
The Biden administration and top Congressional Democrats seek to raise revenue to finance the improvements and other non-infrastructure items in the president’s $2 trillion-plus infrastructure plan, the “American Jobs Plan.” To fund the plan, President Biden advocates raising revenue by materially altering or repealing certain international tax provisions of the Tax Cuts and Jobs Act of 2017, namely the global intangible low-tax income (GILTI) and the base-erosion anti-abuse tax (BEAT). The plan also looks to derail the use of tax havens by advocating for stronger anti-inversion measures and a global minimum tax to end a “30-year race to the bottom” to combat the profit shifting of foreign multinational companies out of the U.S. tax base. This article covers the current steps along the journey to use international tax reform as a revenue raiser to pay for the infrastructure plan.
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