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Document(s) published by this organization: 360


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HTMLEU Disclosure Requirements for Structured Finance Instruments
John Ahern, Neil J. Hamilton, Ulf Kreppel, Drew Salvest, Michelle Taylor; Jones Day;
Legal Alert/Article
October 23, 2014, previously published on October 2014
The European Commission has adopted a final regulation that sets out wide-ranging disclosure requirements for structured finance instruments ("SFIs") in circumstances where the issuer, originator or sponsor is established in the European Union ("EU").

 

HTMLNo Corporate Income Tax on an Undervaluation of Shares Acquired by Belgian Holding Company
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
Following a very long and winding road in several courts, it has finally been confirmed that Belgium cannot impose corporate tax on any undervaluation of or underpayment for shares acquired by a Belgian corporate taxpayer. Thus, when a Belgian corporation buys shares at a price below fair market...

 

HTML"Protectionist" French Excise Tax on Certain Types of Beer Complies with EU Law
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On September 13, 2014, it was reported by the trade press that the European Commission had found that the increase by 160 percent of French excise tax on certain types of high-alcohol-content and luxury beers that was introduced on January 1, 2013 did not fall afoul of the free-market principles of...

 

HTMLTaking a Stand Where Few Have Trodden: Structured Dismissal Held Clearly Authorized by the Bankruptcy Code
Mark G. Douglas, Charles M. Oellermann; Jones Day;
Legal Alert/Article
October 16, 2014, previously published on September/October 2014
A "structured dismissal" of a chapter 11 case following a sale of substantially all of the debtor's assets has become increasingly common as a way to minimize cost and maximize creditor recoveries. However, only a handful of rulings have been issued on the subject, perhaps because...

 

HTMLDraft Guidance for the General Anti-Avoidance Rule
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On July 3, 2014, the State Administration of Taxation (the "SAT") released a discussion draft on the Administrative Measures on the General Anti-Avoidance Rule (the "Draft Measures). The General Anti-Avoidance Rule ("GAAR") was introduced in China Corporate Income Tax Law...

 

HTMLArbitration for One is Not Arbitration for All: Sixth Circuit Allows Lawsuit Against Indirect Parties Following Consolidated Arbitration
Scott W. Cowan, Taylor L. Freeman, Kent W. Lindsay, Andrew D. Ness, Stephen V. O'Neal; Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
Recently, the U.S. Court of Appeals for the Sixth Circuit allowed a subcontractor's lawsuit against design professionals to proceed even though all parties had previously participated in a consolidated arbitration proceeding over the same issues. W.J. O'Neil Co. v. Shepley, Bulfinch, Richardson...

 

HTMLFurther Reference to CJEU on Card Handling Charges
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The First Tier Tax Tribunal has referred certain questions regarding the liability for VAT of card handling charges to the Court of Justice of the European Union ("CJEU") in the case of Bookit Ltd v The Commissioners For Her Majesty's Revenue & Customs.

 

HTMLThree New Tax Treaties Signed by Mexico Will Be Applicable from January 1, 2015
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
During 2014, three new tax treaties signed by Mexico with Peru, the United Arab Emirates, and Malta have been published in the Mexican Official Gazette. According to the tax treaties, their benefits will be applicable from January 1, 2015, bringing Mexico's tax treaty network to 59. Treaties with...

 

HTMLQuestioning the Executoriness of Trademark Licenses in Integrated Agreements
Mark G. Douglas, Laura L. Swanson; Jones Day;
Legal Alert/Article
October 16, 2014, previously published on September/October 2014
Protections added to the Bankruptcy Code in 1988 that give some intellectual property (“IP”) licensees the right to continued use of licensed property notwithstanding rejection of the underlying license agreement do not expressly apply to trademark licenses. As a consequence, a...

 

HTMLTreasury Department and IRS Issue Long-Awaited Inversion Guidance
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets forth rules that are generally effective for transactions completed on or after September 22, 2014, and will be included in regulations that will be...

 


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