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Document(s) published by this organization: 358


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HTMLIRS Issues Guidance Regarding the Deductibility of Litigation Fees Incurred by Branded Pharmaceutical Companies When Defending Their Patents Against Challenges to Market Exclusivity by Generic Companies
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
There is welcome clarity for branded pharmaceutical companies seeking to deduct legal fees incurred in defending their patents against challenges to market exclusivity by generic companies. This clarity comes after a year of uncertainty arising from a negative opinion expressed by the IRS in a...

 

HTMLRepeal of the Interest-Withholding Tax on Certain Cross-Border Loans
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
As a rule, if a nonresident lender grants a loan to an Italian resident borrower, the interest paid on the loan is subject to a 26 percent withholding tax in Italy unless the lender is eligible for the exemption under the Italian laws that implemented the EU Interest and Royalties Directive. The...

 

HTMLPuerto Rico—Although Puerto Rico is an Unincorporated Territory of the United States Rather than a Sovereign, the Financial Troubles of the Beleaguered Caribbean Commonwealth Have Received a Great Deal of Attention Lately.
Mark G. Douglas; Jones Day;
Legal Alert/Article
October 16, 2014, previously published on September/October 2014
On June 28, 2014, Puerto Rican governor Alejandro García Padilla gave his imprimatur to legislation that creates a judicial debt relief process for certain public corporations, including the Puerto Rico Electric Power Authority (PREPA), the Puerto Rico Aqueduct and Sewer Authority (PRASA),...

 

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...

 

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...

 

HTMLParent-Subsidiary Directive
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The Explanatory Memorandum to the Draft Law amending nonresident income tax points out that the main reason for the tax reform is to adapt it, to a greater extent, to the European Union regulatory framework. The draft law includes an anti-abuse clause, similar to the one currently in force, which...

 

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...

 

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...

 

HTMLCommercially Confidential Information at Risk: The European Medicines Agency Issues Disclosure Policy
Christian B. Fulda; Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
As if the fight for reasonable returns on investment into drug development, currently exemplified by the discussion on the pricing of innovative products, is not enough, the pharmaceutical industry is facing one of its biggest challenges in Europe: the protection of commercially confidential...

 

HTMLMexico's New Regulatory Framework for Oil and Gas: Transportation, Refining, Environmental, and Tax
Jose A. Estandia, Mauricio E. Llamas C., William Prescott Mills, Alberto de la Parra Z.; Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
Under the new hydrocarbons legislation, the Comisión Reguladora de Energìa ("CRE," the National Energy Regulatory Commission of Mexico) will have jurisdiction over the transportation, storage, distribution, compression, liquefaction, and decompression of hydrocarbons,...

 


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