The Internal Revenue Service is ready, willing and able to help authorities worldwide with tax enforcement – especially with the sharing of taxpayers’ information. In Zhang v. United States, taxpayers recently appealed a decision from the U.S. District Court for the Northern District of California that denied their petition against an IRS summons for information. The summons was at the request of the Canadian tax authority; the U.S. and Canada have a bilateral tax treaty. The Ninth Circuit Court sided with the...

Read more

The monthly newsletter gives you an overview of recent notable changes in Canadian and American immigration. Here is an overview of the most recent news as of January 31th, 2023. CANADA Prohibition on the Purchase of Residential Property by Non-Canadians Regulations As announced at the end of last year, the Act prohibiting the purchase of residential immovables by non-Canadians came into force on January 1, 2023, and so for the next 2 years. This Act is the result of collaborative work between...

Read more

Key insights Understanding the basic framework of check-the-box regulations can help buyers and sellers identify potential U.S. income tax and reporting risks. A thorough understanding of a U.S. target’s global tax structure can allow buyers to plan for postacquisition restructuring. Accurate reporting of a U.S. target’s global tax structure can allow both buyers and sellers to negotiate tax-efficient deal structuring. Understanding the basic framework of tax classification regulations can help buyers and sellers identify potential U.S. income tax and reporting...

Read more

The EIB is continuing to spearhead market developments in the digitalisation of capital markets with a fully digitally native bond issuance in pound sterling. The £50 million digital bonds, which bear a floating rate of interest, are registered in a private blockchain that ensures privacy and efficiency, while a public blockchain mirror record provides increased transparency on an anonymised basis. The EIB has appointed BNP Paribas, HSBC and RBC Capital Markets as joint lead managers. The digital bonds will...

Read more

The “move fast and break things” mantra, once the loudest guest at tech events in Silicon Valley in California to Dublin’s Silicon Docks is ever closer to being shown the exit. It would seem that EU regulators are relishing their role as the polite but stern doorman. The EU is on a roll these last few years and has been dialling up the regulatory pressure on tech companies of all shapes and sizes. We’ve had updated medical device legislation, the...

Read more

The metaverse may seem far out there for some—almost other worldly. But the reality is that the concept applied to the virtual workplace (aka the officeverse) is quickly gaining some down-to-earth traction amongst companies, especially when it comes to attracting talent that wants unique options for where and how they work. Although the physical office isn’t going anywhere, what’s appealing about the officeverse is its versatility. It has the potential to be the best of both remote work and the...

Read more

FTC’s Proposed Noncompete Ban Highlights Importance of Protecting Trade Secrets On January 5 the Federal Trade Commission (FTC) issued a proposed rule on noncompetes that has a breathtaking scope. The rule, as written, would ban the use of noncompete agreements for all employees, except for those in a very few excluded industries. It has no exceptions for highly compensated or high-level employees and is not only prospective in nature. The proposed rule would also invalidate all existing noncompetes and require...

Read more