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31 Oct 2016, 11:33 am by Daniel Shaviro
  It has addressed broader issues that relate to interest deductions, via the distinction between debt and equity. [read post]
20 May 2016, 6:46 am
The market for corporate control has become increasingly global over the past decades, with cross-border mergers and acquisitions (M&As) now accounting for more than a third of M&A activity worldwide. [read post]
13 Jan 2016, 7:11 am by Daniel Shaviro
 As Herwig Schlunk notes, in his article "The Cashless Corporate Tax" that I believe we discussed at the NYU Tax Policy Colloquium around 15 years ago, the games companies might be expected to play include "the use of [financial] instruments that can avoid the designation of equity. [read post]
5 Oct 2015, 9:09 am by Daniel Shaviro
In the typical case, a U.S. company with U.S. employees who live, say, in California or the Pacific Northwest is creating what it hopes will be valuable intellectual property (IP) that can be profitably exploited worldwide. [read post]
29 Jul 2015, 11:30 am
  But it was not until over a century later, in 1964, that the Xerox Corporation introduced the first commercialized version of the modern fax machine. [read post]
28 Jul 2015, 8:39 am by Tom Smith
The violence of the moves unnerved investors worldwide, stirring fears that the Communist Party may be losing control after stoking a series of epic bubbles in property, corporate investment and equities to keep up the blistering pace of economic growth. [read post]
7 Jul 2015, 11:09 pm by Kevin LaCroix
  The difference from the 2007 activity is that many of the transactions then were driven by private equity firms in the for of leveraged buyouts; the deals this year are being driven by corporate decision-makers looking to execute on larger corporate strategies. [read post]
6 Jul 2015, 6:00 am by Moderator
As a result, critics say, companies artificially minimize their liabilities or even avoid them entirely, and do so legally, thanks to the widely accepted current basis for transfer pricing.With a great deal of scrutiny coming to bear on corporate tax practices worldwide, the Organisation for Economic Co-operation and Development (OECD) is looking at ways to revamp its guidelines on international tax practices. [read post]
4 Jun 2015, 11:30 am by Public Employment Law Press
Stone was a Managing Director and head of the Principal Transactions Group (“PTG”) at Credit Suisse First Boston where he was responsible for the firm’s worldwide real estate effort, including debt origination, equity investments and securitization. [read post]
4 Jun 2015, 11:30 am by The Public Employment Law Press
Stone was a Managing Director and head of the Principal Transactions Group (“PTG”) at Credit Suisse First Boston where he was responsible for the firm’s worldwide real estate effort, including debt origination, equity investments and securitization. [read post]
2 Feb 2015, 2:31 pm by Daniel Shaviro
("ED-Co") earns $100 in the Caymans on which it pays no foreign tax, and $100 in the UK on which it pays $14 of UK tax (I pick this amount since the UK has a 21% corporate tax rate, but also offers tax benefits such as its "patent box" regime that may reduce the amount of tax a given company owes). [read post]
15 Nov 2014, 5:54 am by Daniel Shaviro
  This resembles proposals (just for corporations) to address the distinction between debt and equity by providing an allowance for corporate equity (ACE) – in effect, an imputed interest deduction on equity to match the actual interest deduction for corporate debt – except that Kleinbard would use the COCA in lieu of actual interest deductions, an important distinction from ACE proposals given that financial instruments… [read post]
23 Oct 2014, 12:19 pm by Daniel Shaviro
& foreign, and the question of which of them are the ones to issue new equity and/or make overseas investments. [read post]
7 Sep 2014, 11:00 am by Jim Butler
EB-5 capital is widely used by major hotel brands and some of the largest owners of hotels and restaurants: Marriott International has raised $500 million in EB-5 capital Hilton Worldwide has raised $100 million 4 projects in Washington DC were built with more than $150 million of EB-5 money (including City Market at O, the Marriott Marquis, a Hilton hotel development on New York Avenue and a hotel on E Street that will include a fire station) “I understand why the government has… [read post]
3 Sep 2014, 4:14 am by Kevin LaCroix
The controversy seemed headed for a swift resolution when the Delaware General Assembly quickly moved to act on a measure that would have limited the Supreme Court’s ruling to non-stock corporations (meaning that it wouldn’t apply to Delaware stock corporations). [read post]
27 Jul 2014, 5:30 am by Barry Sookman
Jack (Updated) http://t.co/0Wri0lTosL -> CASL causes decrease in SMS marketing business http://t.co/X687sGP22Z -> Oh Canada (no, Not The Anthem) CASL http://t.co/R4BYJzEkyF -> The result of this law will result in fewer people receiving our exciting offers about the Dolce hotels.http://t.co/r4XaMtZBqK -> Use on domain not infringing official mark Insurance Corporation of BC v. [read post]