When tax-exempt or non-U.S. taxpayers invest in U.S. businesses, unwanted and unintended U.S. tax obligations can follow without careful planning. Blocker corporations have become a common strategy employed...
Obtaining a Phase I environmental site assessment (ESA) is essential to conducting environmental due diligence for commercial real estate transactions. The goal of a Phase I ESA is to evaluate readily...
Artificial intelligence (AI) tools and resources are inundating the news, social media, professional seminars, and inboxes. AI is part of every conversation across industries and professional services...
Do you need guidance in defending against claims brought under the recently overhauled California's Private Attorneys General Act (PAGA)? Read Private Attorneys General Act in California: Defending...
Confidently present your case in chief to the Trademark Trial and Appeal Board (TTAB) with this opening trial brief that an opposer/petitioner (plaintiff) may use in an opposition or cancellation proceeding...
This practice note discusses the principal U.S. federal income tax consequences to a private fund and its investors of owning common stock or American Depository Shares (ADSs) of a foreign corporate issuer. This practice note assumes that the private fund is taxable as a partnership for U.S. federal income tax purposes and that investors are not pass-through entities; they are either U.S. individuals or U.S. organized corporations for U.S. federal income tax purposes. While non-U.S. investors can invest in U.S. partnerships and funds, this practice note does not delve into the tax consequences of non-U.S. investors who hold stock of foreign issuers indirectly through a U.S. fund. Read Now »
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