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Articles by Nancy O'Neil
2023 Doing Business in the United States
The U.S. is one of the easiest jurisdictions in the world in which to do business. Regulatory barriers are generally low, establishing a branch or business entity is quick and easy, labor and employment laws are much more employer-friendly than in most other developed economies, and the legal system is well-developed and transparent.
Land of opportunity - why Australian investors are being drawn to the United States
Billions of dollars worldwide are pouring into the transition to green energy, no more so than in the United States (U.S.) where new legislation is providing a powerful stimulus. For Australian investors, the opportunity to invest in the U.S, and benefit from a raft of green tax incentives, may be too good to resist. At the core of the effort is the U.S. government's unprecedented support for energy transition.
U.S. tax alert: Inflation Reduction Act, CHIPS Act & Private Capital | JD Supra
Clean Energy Incentives One pillar of the IRA is its provision of $369 billion in "energy security and climate change" investments over the next 10 years.
Final regulations – U.S. withholding tax on transfers of partnership interests | JD Supra
Since 2018, the buyers, sellers, and partnerships engaging in secondary and other transactions involving partnership interest transfers have been navigating complicated U.S. tax and related withholding obligations that apply when a non-U.S. partner transfers an interest in a partnership that is engaged in a U.S. trade or business. Please see full Publication below for more information.
Final regulations - Foreign partner's U.S. tax liability on transfer of partnership interest | JD Supra
Given the overall development of the secondaries market and the increasing volume and size of secondary funds, the U.S. tax and withholding regime that applies to a foreign partner transferring an interest in a partnership that is engaged in a U.S. trade or business, enacted as part of 2017 U.S. tax reform, has become an important consideration in structuring and negotiating secondary transactions, even those transactions that do not involve U.S. investments.
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