Foreign investors in US partnerships had reason to celebrate last month when a major tax court decision rejected the controversial Revenue Ruling 91-32, which stipulates that gains of a non-US partner from the disposition of an interest in a partnership engaged in US trade or business is treated as a sale of partnership assets and subject to US income tax.   In Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, the court ruled that treating the gains as “ECI” (income effectively...

Wilson Sonsini Goodrich & Rosati’s 2017 Mid-Year Technology and Life Sciences IPO Report presents key data related to the pricing of 26 U.S.-based technology and life sciences issuers between January 1 and June 30, 2017. Just as the overall volume of IPO activity has increased during the first half of 2017, compared with the same period in 2016, the number of IPOs by issuers from the technology and life sciences sectors has been proportionally robust. Read the Full Report here.

By Maia T. Spilman, Esq./CIPP The “GDPR” –What is it and why does it matter if we’re not in Europe? The Data privacy/Data protection community has been all abuzz about the European Union’s “GDPR” for a while and the attention will not go away soon.  Apart from those of us who are data privacy/protection focused in our jobs, many companies that handle electronic data are also joining the conversation.  In this column we’ll attempt to provide an overview of the “GDPR”...

United States View New York State– AGGRIEVED---BUT ARE YOU THE PROPER PARTY? In the recent court decision in the matter of Larchmont Pancake House v. Town of Mamaroneck, the New York State Appellate Division (the intermediate court) dismissed tax protest proceedings brought in the name of the operator of a restaurant.  The court held that even though the petitioner was an aggrieved party given that the taxes had a direct impact on its pecuniary interests, because it was not the property...

On August 25, 2017, the U.S. Citizenship and Immigration Services (USCIS) confirmed that, as part of President Trump’s “extreme vetting” directives, potential legal immigrant workers will be required to undergo in-person interviews with USCIS. The interview requirement will apply to anyone moving from an employment-based visa to lawful permanent residency. The new mandate will also require visa holders who are family members of refugees or individuals who receive asylum to undergo an in-person interview when they apply for provisional...

Impact on American Business, Tourism and Diplomacy Devastating; New Study Shows Program Strengthens U.S. Economy Washington, DC (August 27, 2017) – At a time when the world’s favorability rating of the United States hovers below 50 percent, a small working group based in the White House is seeking to eliminate the majority of privately-funded J1 Exchange Visitor Programs. As reported today in the Wall Street Journal, American businesses fear the economic blow they will experience as a result of this effort.  Started...

Client name ASML Holding N.V. – seller Other parties involved Kulicke & Soffa Industries Inc.; Liteq B.V. Nature of transaction Liteq develops chip packaging machines that work on the basis of lithographic methods, a new way of packaging, enabling the chip industry to respond to the semiconductors always becoming smaller and thinner. Liteq's technologies were developed through close cooperation of several technology, financial and developmental organizations within the region including ASML Netherlands BV, Beltec Holding BV, the Brabant Development Agency (BOM), Sioux, Random Capital BV...