If passive foreign investment company (PFIC) issues are involved, the amended tax returns submitted as part of the final OVDP packet will need to be modified to reflect the statutory PFIC computations (rather than the specialized mark-to-market computations within the OVDP).
Second, the suspension of the 3-year statute of limitations is expanded to (1) annual reports required to be filed by a Passive Foreign Investment Company (PFIC), (2) the election of a PFIC shareholder to have the PFIC treated as a qualifying electing fund and (3) reports of foreign financial assets (a new form to be attached to and made a part of a tax return).
Our establishment of a foreign exchange investment company will not have any adverse effect on dollar-denominated assets.
The day before his Dec. 1 swearing-in, Pena Nieto and his team got the three main political parties to sign a 94-point national legislative agenda known as the Pact for Mexico that promises everything from efficient harvesting of rainwater to opening Mexico's behemoth state oil company to private and foreign investment.
According to OFII, the foreign investment estimates include equity capital, reinvested earnings and inter-company debt (U.S. subsidiaries borrowing from foreign parent companies).
Until January the company's "ring fence" kept foreign investment below 20%, and the scarcity value of Western shares gave them a 40% to 50% premium above their Moscow price.
Alibaba recently transferred ownership of the unit to Alibaba CEO Jack Ma, a move the company said was necessary to comply with Chinese regulations barring foreign investment in domestic online payment services.
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This allowed the new business, once local-government approval was obtained in China, to accept foreign private-equity money invested into the overseas holding company, while abiding by the letter of Beijing's restrictions on foreign investment in domestic enterprises.
Contrary to public opinion, which tends to regard foreign investment by German companies as a job-killing act of economic treachery, the car company says that the increase is due partly to its new factory in the United States.
After several days of defiance, Chinese telecom equipment manufacturer Huawei announced Monday that it would abide a recommendation from the Committee on Foreign Investment in the United States (CFIUS) that it divest of U.S. technology company 3-Leaf.
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This afternoon, the Committee on Foreign Investment in the United States (CFIUS) will hold discussions with representatives of the Netherlands' company known as ASML, the world's second largest manufacturer of lithography machines used to produce high-quality silicon chips.
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Unfortunately, that seemingly sound advice may not have reached Ralls Corporation, a Chinese-owned company that named President Obama, Treasury Secretary Geithner, and the Committee on Foreign Investment in the United States (CFIUS) in a lawsuit recently filed in a District of Columbia federal court.
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The data reflect investments that meet the threshold for foreign direct investment, which is a final stake of 10 percent or more of voting rights in the invested company and excludes portfolio investments such as government bonds.
Huawei and former 3Leaf executives say they didn't think the acquisition required a review by the Committee on Foreign Investment in the U.S., or CFIUS, because they didn't buy all of the company's assets.
An investment from In-Q-Tel led Hoffman's company, which makes software that analyzes foreign-language texts, to expand to Middle Eastern languages, and it now does business with a variety of federal agencies, including the NSA. He says that IQT is also well regarded in Silicon Valley because of its successful investing track record.
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