Foreign persons1 are generally not subject to Federal income tax on gains from the sale of a capital asset located in the United States, unless the capital gains are effectively connected with the conduct of a United States trade or business.  Internal Revenue Code (IRC) Section 897, which came online with the passing of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), created a special rule for a gain derived by a foreign person from the disposition...

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The U.S. Department of State recently announced that it is developing the capability to issue digital visa authorizations (DVA) instead of the traditional visas that are printed and placed in applicants’ passports. This development would streamline the travel authorization process by automating the transfer of data from visa application, to airline verification, to border inspection, and U.S. admission. Following unprecedented backlogs for visa interviews at U.S. consulates in the wake of the COVID-19 pandemic, the DVA pilot program appears to...

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The EU Markets in Crypto-Assets Regulation ("MiCA") was published in the Official Journal of the European Union on 9 June 2023 and entered into force on 29 June 2023. Crypto-asset service providers ("CASPs") need to be MiCA compliant by no later than 30 December 2024. It is notable that the requirements applicable to issuers of asset-referenced tokens and e-money tokens (Title III and IV MiCA) will already enter into force six months earlier, on 30 June 2024. In addition, Member States...

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Matching florescent hues can be challenging, but digital strategies can help manage the process.Designers and colorists know how difficult it can be to get fluorescent colors right. Yet it’s also undeniable that these colors have a very strong draw on consumers across multiple categories, including sportswear, swimwear, and more. So despite the difficulties they present, the payoff can be great. But what makes fluorescent colors so hard to achieve? Shedding Light  On The Challenge Most colors become darker as more dye or...

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Welcome to our little Swiss Dish. Where we give you insights of Switzerland’s economy in a cheesy way. Grab your binoculars and a fashionable outfit because in this publication we are outdoors. Training, planning and, nutrition preparation: Today we will talk about one of the most common leisure activities of Swiss people - hiking. Everyone has done it at least once in their lifetime. May it be during a school excursion, military service or, with family and friends. Switzerland offers...

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September 14, 2023, the IRS issued an announcement that it was pausing processing new employee retention credit claims through year-end so it could put in place measures to better detect fraudulent claims, amidst a continued influx the last few months. See a brief summary of the release here. How will this impact your nonprofit? Claimed and Collected: If you previously consulted with a qualified tax advisor, claimed ERC, and received full payment from the IRS, this announcement should have minimal impact...

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The European Commission published a new package of proposals on 12 September to put forward (i) a single set of tax rules for doing business in the EU (Council Directive on Business in Europe: Framework to Income Taxation (BEFIT)), (ii) harmonised transfer pricing rules within the EU ( Council Directive on Transfer Pricing) and (iii) a Head-Office Tax system for micro, small, and medium-sized enterprises (SMEs) (Council Directive establishing a Head Office Tax system for micro, small, and medium-sized enterprises,...

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Released on September 8, 2023, IRS Notice 2023-63 provides wide-ranging and potentially controversial guidance on the capitalization and amortization of research and experimentation expenses under section 174.The Notice addresses several key questions on capitalization under section 174, which is required for tax years beginning on or after January 1, 2022: When are amounts paid by a service provider in a contract research arrangement subject to capitalization rules? How do the rules apply to R&D costs incurred as part of a...

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Built in 1968, 140 Broadway located in New York City is a stunning Class A vintage office building. Although it has stood in the center of lower Manhattan for more than 50 years, thoughtful planning, a clear vision and collaborative partnership have wiped away the years by proactively repositioning this iconic office building with state-of-the-art amenities. The same thing can be said for One Victory Park and International Plaza in the Dallas area. Tricked out amenity floors using underutilized space...

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Last week, the California Legislature passed two bills, together the "Climate Accountability Package," that would mandate the public disclosure of greenhouse gas emissions (GHG) and climate-related financial risk by companies doing business in California that meet different revenue thresholds. California Governor Gavin Newsom has indicated he will sign the bills into law, subject to "some cleanup on some little language," the details of which remain undisclosed.1California is the first governmental actor in the United States to mandate corporate climate-related...

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