The EC’s investigation focused on tax rulings issued by the Luxembourg tax authorities between 2008 and 2014, which confirmed the tax treatment of certain mandatorily convertible instruments (‘instruments’) issued by two Luxembourg group subsidiaries (‘borrowers’) to two other Luxembourg companies of the group (‘lenders’). The rulings were confirming the following tax treatment: the borrowers treated the instruments as debt and recorded in their accounts accretions which were deductible at their level; the lenders entered into a forward sale agreement...

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With winter approaching, we are delighted to present our December business update. In this edition, aligned with our bi-monthly tradition, we have curated a range of insightful topics tailored for your U.S. subsidiary. As we gear up for 2024, we have updates relevant to the upcoming year.Topics covered:Sales Tax Rate Changes | Payroll & Benefits: Update on 2024 IRS Limits & Navigating Health Insurance Landscape | Navigating End-of-Year Tax Prep | Update on Beneficial Ownership Reporting | FDA News | Client Success Story | Action...

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Will COP28 achieve a commitment to phase-out fossil fuels? The 28th United Nations Climate Change Conference (COP28) is currently taking place in Dubai, United Arab Emirates. It will bring together parties worldwide to refocus the global climate agenda as the deadline for climate targets for 2030 get closer. This year's conference includes the first global stock take of the Paris Agreement that will assess how successful its implementation has been so far. Based on the results, the participating parties will create...

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Year end is a good time to explore strategies to unlock potential tax saving opportunities. This is especially true in 2023, when high interest rates and the upcoming expiration of certain tax benefits make some strategies particularly beneficial. What tax strategies businesses should consider before year end 2023, including changing your accounting method, the timing of fixed asset purchases, and business succession planning? Weigh accounting method changes considering high interest rates There are pros and cons to changing accounting methods, which can...

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Under the Security and Exchange Commission’s (SEC) new cybersecurity disclosure regulations, public companies will be required to file an “Item 1.05 Material Cybersecurity Incidents” Form 8-K to report any material “cybersecurity incidents,” which are defined as “an unauthorized occurrence, or a series of related unauthorized occurrences, on or conducted through a information systems that jeopardizes the confidentiality, integrity or availability of a information systems or any information residing therein.” Accordingly, the SEC’s broad definition of a “cybersecurity incident” may...

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Cushman & Wakefield (NYSE: CWK), a leading global commercial real estate services firm, proudly announces that it received a score of 100 on the Human Rights Campaign Foundation’s 2023-2024 Corporate Equality Index (CEI), the nation’s foremost benchmarking survey and report measuring corporate policies and practices related to LGBTQ+ workplace equality. “Cushman & Wakefield is proud to receive the Equality 100 Award: Leader in LGBTQ+ Workplace Inclusion. Being recognized for this award is a testament to our commitment to diversity, equity...

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On November 29, 2023, a Ninth Circuit panel affirmed the lower court’s decision in Briskin v. Shopify, limiting the court’s jurisdictional reach against e-commerce platforms alleged to have violated privacy and unfair competition laws. In a case of first impression, the court was asked to decide whether defendant Shopify’s data collection and tracking practices exposed it to personal jurisdiction in California. The court decisively held that “hen a company operates a nationally available e-commerce payment platform and is indifferent to the...

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In November, $79.2 million across 10 loans were resolved with $36.4 million in losses total, carrying an average loss severity of 45.92% for the month. This was a decrease in loan loss volume from October where losses totaled $155.6 million. The 12-month average disposed balance moved to $194.0, down from the $209.3 million that was seen last month, while the 12-month moving average loss severity stood at 53.99% in November, slightly up from the 53.21% seen in the prior month. This...

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In 2004, Alberta's Transmission Regulation established the framework for the planning and development of Alberta’s electricity transmission infrastructure. Its intent was to attract new generation, increase competition and serve expected increases in load. The regulation has remained largely unchanged since 2004. Meanwhile, the electricity system has experienced significant changes—in part due to the dramatic increase in the amount of intermittent renewable power generation facilities connecting to the grid. As a result, Alberta has embarked on a consultation process to modernize the...

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