Archive for July, 2011

New Jersey continues to be a hot bed of activity in the pharmaceutical and healthcare industries.  New Jersey Lieutenant Governor Kim Guadagno noted today that two days of trade meetings with Chinese companies have resulted in more than $1 Billion in trade agreements for pharmaceutical and health care companies.  Companies from the Zhejiang Province in China paired with New Jersey companies at a trade conference held at William Patterson University in Wayne, and Kean University in Union, New Jersey this week. New Jersey and Zhejiang already have pharmaceutical relationships. Novartis conducts business in Zhejiang and Zhejiang-based HiSun and CSPC have launched subsidiary operations in Princeton and New Brunswick, respectively.

For further details, see http://www.njbiz.com/article/20110721/NJBIZ01/110729976/-1/enews_dailyT4

Live from New York, it’s Day Two of the NYU Advanced International Tax Seminar.  Today, we’re focusing on U.S. outbound transaction planning and investment issues that affect those of you looking to establish a presence off shore (e.g., a subsidiary or branch) to take advantage of foreign markets or lower tax jurisdictions; perhaps you’re thinking about moving your intellectual property abroad and re-licensing it back or to others – that’s a hot button issue with Internal Revenue Service and is the subject of their “Excess Return Proposal.” The proposal under President Obama 2012 Budget to tax excess returns or intangibles specifies the types of activities that constitute a transfer of intangibles for purposes of computing Subpart F income. The Joint Committee on Taxation pointed out that in contrast to the prior proposal, the current version relies not on the date of the transfer of intangible property, but rather on the date of the transactions that are connected with or benefit from a covered intangible. The current proposal applies to all such transactions occurring after December 31, 2011.

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Will the Interest Charge Domestic International Sales Corporation (IC DISC) survive the budget and debt ceiling negotiations in Washington?  Notwithstanding that both Congress and President Obama agree that a strong manufacturing and export base is important to U.S. economic recovery, will the Internal Revenue Code (IRC) be amended to cut back or eliminate the benefits of the IC DISC as part of the budget/debt ceiling negotiations in Washington?

The IC DISC remains, at least through 2012, or sooner if its tax breaks go on the chopping block in Washington, as one of the last big tax break for U.S. companies exporting their wares.

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We’re in NYC today where the New York University Summer Institute in Taxation kicked off its Advanced International Taxation Seminar.  Today’s highlights include cutting edge treaty issues and some new planning techniques to minimize the tax impact on businesses and individuals engaged in cross border transactions.  We’re discussing a number of  international mergers and acquisitions issues that come straight from recent articles in the Wall Street Journal.  Of particular interest for many of you inbound real estate investors are tax issues relative to  cross border real estate transactions.  We’ve found invaluable practical advice regarding the choice of entity for certain investments and considerations in making your equity infusions.  Let us know if we can offer you guidance with respect to your cross border mergers and acquisitions and U.S. real estate investment matters.  Stay tuned for tomorrow’s posting.

In a recent Anonymous hacking mission dubbed #OpMonsanto, the hacker group attacked Monsanto, an international agricultural corporation by hacking into Monsanto’s system and releasing data concerning over 2,500 employees and connections.  Anonymous also took down Monsanto’s mail server and web assets and says it plans to create a Wikipedia page to store and organize the stolen information.

Anonymous has also released a statement proclaiming the soon-to-be targets for an operation called “Project Tarmeggedon.”  Anonymous is using this mission to victimize the companies involved in theAlberta,Canadaoil sands development because of concerns that extracting oil from sand particles can be extremely damaging to the environment. Some of these targets include: Royal Bank ofScotland, Imperial Oil, Exxon Mobil, ConocoPhillips, and Canadian Oil Sands Ltd.

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The New York Times just reported that The News of the World newspaper is to be shut down after a final ad-free Sunday copy this upcoming weekend.  According to press accounts, News Corp.’s The News of the World has been under police probe over the hacking of many celebrities’ and politicians’ telephones.  In 2007, World investigators were sentenced to prison for intercepting messages of the Royal Family.  The confiscated notebooks of these investigators have provided information and evidence for these phone hackings and more.

Recently, the World allegedly had been intercepting and deleting messages from the voicemail of Milly Dower, a British girl who was kidnapped and murdered in 2002.  Additional allegations include paying off the police, lying to the British Parliament, and interfering with a murder investigation.

British leaders have been pushing for the government to delay News Corporation’s takeover of BSkyB.  Reportedly, Prime Minister David Cameron has stated that News Corp. will have to prove it is “fit and proper” for a broadcast license before the acquisition of BSkyB.  Murdoch has claimed his company will be “fully and proactively” cooperating with the police investigation.

^{Priya Amin contributed to this post.}

Sources:

http://www.nytimes.com/2011/07/08/world/europe/08britain.html?pagewanted=2&_r=1&hp&emc=na

http://www.nytimes.com/2011/07/05/world/europe/05britain.html?ref=rupertmurdoch

http://www.hollywoodreporter.com/news/ford-rupert-murdoch-news-world-208239

http://www.hollywoodreporter.com/news/rupert-murdoch-speaks-phone-hacking-208285?utm_source=SilverpopMailing&utm_medium=email&utm_campaign=Robert%20Murdoch%20(1)&utm_content=