Publication
M&A outlook: What can we expect in 2025?
M&A activity was subdued through 2023 and 2024 but, with the recent uptick in activity, have we finally turned the highly anticipated corner and can we now see a brighter future for M&A in 2025?
Foreign nongrantor trust for US beneficiaries: dos and don’ts
United States | Publication | April 2022
The throwback tax is the US tax law’s main tool for discouraging tax-free accumulation of income by foreign non-grantor trusts for US beneficiaries. Its complex rules are a dangerous minefield that should be avoided. This article reviews the operation of the throwback tax rules, and assesses the effectiveness of this trust anti-deferral regime in various fact patterns. It also discusses how the trust anti-deferral regime interacts with the US law’s foreign corporation anti-deferral regime, another minefield.
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Co-head of Tax, United States
Email
bill.cavanagh@nortonrosefulbright.com
Recent publications
Publication
Ireland
The Screening of Third Country Transactions Act 2023 (the “Act”), which establishes a new foreign direct investment ("FDI") screening regime in Ireland, was enacted on 31 October 2023, and the much-anticipated commencement date of the Act has now been confirmed to be 6 January 2025.
Publication
Intel judgment - more than one way to skin a rebate?!
On 24 October 2024, the Court of Justice of the European Union (CJEU) confirmed that the European Commission’s (the EC) 2009 decision, which imposed a (then record) €1.06 billion fine on Intel, was flawed as far as it found that loyalty rebates granted by Intel had anti-competitive effects.
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