Succession planning is a critical aspect of managing small, closely held businesses, as the unexpected departure of a key leader can significantly disrupt operations and challenge the business's legal...
Entering into a letter of intent for an office lease agreement? Consult our playbook for valuable key provisions, alternative language provisions, and guidance for both landlords and tenants. Download...
In the complex world of M&A transactions, transition services agreements (TSAs) serve as critical bridges between deal closing and operational independence thus creating stability during organizational...
This practice note covers key legal and regulatory issues to evaluate, questions to ask, and documents to review in medical device or diagnostic technology deals, including M&A, investments, financings...
The U.S. branch profits tax (BPT) is a critical component of the federal tax system, ensuring foreign corporations with U.S. branches face a tax burden similar to U.S.-incorporated subsidiaries. Imposed at a 30% rate on the "dividend equivalent amount," the BPT deters profit shifting by taxing profits not reinvested into branch assets. Introduced by the Tax Reform Act of 1986, it aligns the taxation of U.S. branches with domestic subsidiaries, preventing foreign entities from repatriating earnings without similar taxes. This practice note explores the BPT's complexities and treaty impacts, providing a guide for optimizing global tax strategies.
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