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Document(s) published by this organization: 427


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HTMLRetroactivity of the Limitation on the Deductibility of Capital Losses
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
On May 7, 2015, the Conseil d'Etat requested from the Conseil constitutionnel, on behalf of a French bank, a QPC on the conformity to the French Constitution of Article 18 of the Amending Finance Law for 2012 dated August 16, 2012 (Finance Law for 2012), which introduced a limitation on the...

 

HTMLExceptional Depreciation of Industrial Assets 
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
The French Government introduced as part of its bill for growth and activity (Projet de loi pour la croissance et l'activité, or Projet de loi Macron, Macron Draft Law) a new measure aiming at boosting industrial investment in France: an exceptional additional 40 percent depreciation of...

 

HTMLTreatment of Foreign Nonprofit Organizations 
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
As discussed in previous French Tax Updates (see June 2014 and February 2015), the treatment of French source dividends paid to foreign nonprofit organizations (NPOs) raises the issue of comparability of NPOs with French nonprofit organizations. The practical impact of the analysis is that, in the...

 

HTMLU.S. Treasury Department Releases Proposed Model Treaty Provisions
Lodewijk P.W. Berger, Patrick J. Browne, Joseph A. Goldman, Karl L. Kellar, Raymond J. Wiacek; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the "Model Treaty"), which was last updated in 2006. The Model Treaty is the template that Treasury...

 

HTMLDigital Health Law Update, Vol. I, Issue 3
Stephen E. Gillette, Alexis Slagle Gilroy, Kevin D. Lyles, Cristiana Spontoni, Soleil E. Teubner; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
On May 19, 2015, Alabama and Minnesota became the seventh and eighth states, respectively, to enact the Interstate Medical Licensure Compact, joining Idaho, Montana, Utah, South Dakota, Wyoming, and West Virginia. Adoption by the seventh state means the Compact is now effective for the adopting...

 

HTMLScope of the Former 40 Percent Tax Basis Relief on Dividends
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
Under the relevant French tax rules in force until 2012, individual shareholders domiciled for tax purposes in France could benefit from a 40 percent tax basis relief on the amount of dividends subject to the progressive tax scale of French personal income tax (up to 45 percent), unless they had...

 

HTMLRecent Requests For Priority Preliminary Rulings
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
An application for a priority preliminary ruling on the issue of constitutionality (Question prioritaire de constitutionnalité, QPC) is the right of any person who is involved in legal proceedings before a court to argue that a statutory provision infringes rights and freedoms guaranteed by...

 

HTMLDoing Business with the Government? What You Should Know about Cybersecurity
Peter F. Garvin, J. Andrew Jackson, Fernand A. Lavallee, Todd S. McClelland, Mauricio F. Paez; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
Government contractors are in a difficult position when it comes to cybersecurity. Not only do they need to worry about cybersecurity issues that affect almost every company, but they also often house sensitive government data that can carry additional obligations. Further, the very fact that they...

 

HTMLDeadline Extended for New Filers of Mandatory Economic Survey of U.S. Investment Abroad
Chad O. Dorr, Laura L. Fraedrich, Chase David Kaniecki, Lindsey Michelle Nelson, Donald G. Yeargin; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
Last month, we alerted U.S. companies with foreign subsidiaries and branches to the impending deadline for the U.S. Department of Commerce, Bureau of Economic Analysis ("BEA") Benchmark Survey of U.S. Direct Investment Abroad, also known as the "BE-10" survey. A copy of that...

 

HTMLDebt-Push-Down Challenged Under Abuse Of Law Theory
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
June 8, 2015, previously published on June 2015
In a decision issued few weeks ago (CAA Versailles, April 14, 2015, SAS Ingram Micro), the Versailles Administrative Court of Appeals (CAA) took position on a debt-push-down financing which has been challenged by the French tax authorities, as from 2008, under the abuse of law theory (abus de...

 


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