- In the recently published Revenue Ruling 2014-18, the Internal Revenue Service (IRS) concluded that certain nonqualified stock options (NSOs) or stock appreciation rights (SARs) would not be subject to the anti-deferral rules of Internal Revenue Code section 457A (section 457A). Generally, section 457A prohibits the deferral of income for service providers that perform services for nonqualified entities (i.e., foreign corporations based in offshore tax havens, entities substantially owned by tax-exempt organizations, or other tax-indifferent parties).
- Recently, project sponsors have combined New Markets Tax Credits with EB-5 financing in order to strengthen the overall financing structure of the projects. While significant benefits can be achieved, several structuring challenges need to be overcome.
- This presentation discusses a framework for expansion into the European Union, including the financial and legal benefits, risks, and ramifications of expanding into Europe.
- Despite the economic developments in major parts of the country, and modern Chinese people’s increasing appetite on adopting western styles of living, China is still a country with a very special character of its own. Insight in Chinese traditions and habits and careful preparations prior to any important meetings are essential, even for the experienced executive.
- Foreign financial institutions should become FATCA compliant as soon as possible to avoid penalties.
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