In a stock purchase transaction, the outstanding stock of the target company is transferred directly by its stockholders to the purchaser, with a stock purchase agreement serving as the primary governing...
Recreational cannabis continues to gain in popularity as more states legalize its use. To meet this growing demand, an increasing number of landlords are renting space to cannabis retail businesses. Both...
This practice note explains whether and how drug, medical device, biologics, and other life sciences companies should include ADR mechanisms in their contracts to resolve commercial disputes. Read now...
Do you need to understand when a U.S. employer may have to comply with U.S. labor and employment laws extraterritorially and when a foreign employer with operations in the United States is responsible...
Read this new practice note by Daniel Swanson and Julian Kleinbrodt from Gibson, Dunn & Crutcher to get up to speed on antitrust risks in intellectual property licensing. Leverage legal strategies...
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The Internal Revenue Service and the Department of the Treasury have released new final foreign tax credit regulations. 87 Fed. Reg. 276 (Jan. 4, 2022). The regulations overhaul what it means for a foreign tax to be claimed as a credit. Under the new rules, you now must determine whether the foreign tax satisfies a new “attribution requirement” for it to be creditable under I.R.C. Sections 901 or 903. Taxpayers and practitioners should evaluate the creditability of a tax by examining the tax imposed by a foreign country on income to ensure it has sufficient nexus to an activity in that foreign country (for example, operations, employees, factors of production). If the sufficient nexus test cannot be met, then the tax is not creditable.
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