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Member News
Member News
11
Dec
What happened?
Treasury and the IRS on December 4 issued three Notices—2025-75, 2025-77, and 2025-78—providing early guidance on several international tax provisions enacted as part of the One Big Beautiful Bill Act (the Act or OBBBA).
Notice 2025-75 announces the intent to issue proposed regulations implementing the transition rule under Section 70354(c)(2) of the Act. The transition rule affects how Section 951(a)(2)(B) reductions apply for certain dividends paid by controlled foreign corporations (CFCs) in tax years beginning before January 1, 2026.
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10
Dec
The big news in the mergers and acquisitions world late last week was Netflix Inc.'s agreement to buy Warner Bros. Discovery Inc. in a deal valued at $82.7 billion.
The acquisition would create an entertainment behemoth, if it passes regulatory muster. Netflix would come to own the Sopranos, Big Bang Theory, and Game of Thrones franchises. More importantly to those in the commercial real estate world, it would assume Warner's studio movie-making chops. And that’s where the potential headaches come up.
Warner has been among...
10
Dec
Artificial intelligence (AI) has dramatically expanded the toolkit available for reverse engineering, and in-house counsel might wish to take note. Reverse engineering is the process of discovering otherwise nonpublic information about a product by examining the public-facing product. Reverse engineering has always presented a risk, but rapidly-evolving technology is expanding the scope of what can be reverse-engineered. Now, AI enables reverse engineering in previously-impossible ways. What once required specialized expertise and significant time investment can now be accomplished in...
09
Dec
As we await a Supreme Court ruling on the validity of the tariffs, the Court of International Trade is seeing a wave of protective lawsuits.
A growing number of companies — following the lead of Costco — are filing protective lawsuits in the U.S. Court of International Trade (CIT) to preserve their right to refunds if the Supreme Court strikes down the Trump administration's emergency-based tariffs.
If your company paid tariffs International Emergency Economic Powers Act (IEEPA) in 2025, you should...
09
Dec
In this week’s Roar: Asia’s changing manufacturing economy, U.S. production contraction, the effect of unpredictable trade policies, a potential two-tier market for container shipping, and more hackers are targeting global supply chains.
Signs of who will be the winners and losers from the trade wars are emerging. Asia’s key manufacturing economies were sluggish in November, with PMIs showing contraction in China, Japan, South Korea, and Taiwan, despite what appears to be meaningful progress in U.S. trade negotiations. But it’s not all bad news,...
08
Dec
A major U.S.-based importer recently filed suit in the U.S. Court of International Trade (CIT) to preserve its ability to recover tariffs imposed under the International Emergency Economic Powers Act (IEEPA) that it has already paid. The suit does not just ask that the underlying IEEPA tariffs be declared unlawful; it asks the court to: (1) prevent U.S. Customs and Border Protection (CBP) from “liquidating” affected entries while the litigation is unresolved; and (2) preserve the importer’s path to...
08
Dec
French biotech Cilcare is the winner of the 2025 Enterprise Europe Network (EEN) Awards, announced at the Network’s Annual Conference in the Danish city of Aalborg on 28 November, rewarding its success in leveraging EEN support to develop its achievements in hearing loss research.
Millions of people around the world suffer from hearing loss, yet effective treatments remain limited. Cilcare, founded in 2014 by three women entrepreneurs, set out to meet this challenge by developing advanced therapies for hearing disorders,...
05
Dec
Tariffs are by no means a new phenomenon, but recent developments have had a profound impact on global supply chains and international trade. From the US tariff waves introduced under the Trump administration to the retaliatory measures imposed by key trading partners, including the European Union, protectionist policies have re-emerged as a defining feature of the international trade landscape. As tariffs represent a cost in the supply chain, these may trigger important transfer pricing considerations for multinational enterprises.
In light...
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