Private equity transactions refer to investments (and the sale or disposition of those investments) made by pooled investment vehicles (a private equity fund, venture fund, or other group of institutional...
Commercial Property Assessed Clean Energy (C-PACE) financing provides borrowers access to additional capital for constructing energy-efficient improvements. Private lenders offer C-PACE financing in most...
In the United States, federal and state banking laws and the regulations promulgated by federal and state banking regulators provide a comprehensive system that regulates and supervises the activities...
Learn about the litigation process set up by the Biologics Price Competition and Innovation Act (BPCIA) to facilitate resolution of patent disputes between reference product sponsors and biosimilar manufacturers...
Do you need to understand child labor law compliance best practices in light of recent developments in this area of the law spearheaded by Congress, the Department of Labor, and other federal and state...
Congress enacted the passive foreign investment company (PFIC) rules in 1986 to limit U.S. persons from deferring U.S. federal income tax by foreign investment. Certain U.S. persons would invest in foreign corporations then convert ordinary income derived from these investments to capital gains upon disposition. The PFIC rules work together with the controlled foreign corporation (CFC) rules as the main anti-deferral provisions within the tax code. In general, a foreign corporation is considered a PFIC if (1) at least 75% of its gross income is passive income (having earnings made through investments rather than regular business operations), or (2) at least half of its assets produce passive income. This practice note discusses the key differences between the proposed, final, and new proposed regulations, and how these rules may subject your clients to U.S. federal income tax. If your client has overseas insurance affiliates, take heed; Treasury is now considering the necessity of changes for a test to determine whether offshore insurance businesses fall under the PFIC tax regime.
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