On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked…
The Health Pod, Baker McKenzie’s industry podcast series, highlights sector-specific issues and trends that affect healthcare and life…
In brief The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) (TCJA) made significant changes to…
On October 2, 2020, the Small Business Administration (SBA) published a long-awaited procedural notice that provides further clarity on procedures for changes of ownership of an entity that has received Paycheck Protection Program (PPP) funds. The procedural notice (i) identifies when a change of ownership will be deemed to have occurred, (ii) specifies the reporting obligations of PPP borrowers in connection with such change of ownership, and (iii) provides guidance as to whether the SBA’s prior approval is required. Notably, the procedural notice does not provide any relief to PPP borrowers with change of ownership transactions that were closed prior to October 2, 2020.
On October 9, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the comment period for the advance…
On October 1, 2020, the US Department of the Treasury (“Treasury”) issued a pair of advisories to alert companies about risks…
Yesterday U.S. Customs and Border Protection (CBP) issued its first finding of forced labor in 24 years (Finding) against importation into the United States of certain goods from a Chinese company. The Finding was made pursuant to 19 U.S.C. 1307, which prohibits the importation of merchandise mined, manufactured, or produced,…
In a significant regulatory action, the US Securities and Exchange Commission (SEC) recently proposed to issue an order granting certain “finders” a conditional exemption from broker-dealer registration in connection with capital raising activities in private markets (“Finders Proposal”). The Finders Proposal seeks to address the long-standing regulatory uncertainty surrounding the status of intermediaries in the private capital-raising markets and to encourage investment in small businesses, which disproportionally rely on finders to locate capital. The proposed exemption would allow natural persons to engage in certain limited activities involving accredited investors without registering with the SEC as brokers under the Securities Exchange Act of 1934 (“Exchange Act”).
Shelter-in-place or stay-at-home orders have been prevalent throughout the United States since March 2020 as state and local governments have sought to protect their citizens from the spread of the COVID-19 virus while at the same time reopen their economies in accordance with phased reopening plans. Keeping abreast of the evolving nature of these orders and plans as the spread of the virus continues to evolve is critical to the functioning of all businesses throughout the country.
In brief On September 24, 2020, the Franchise Tax Board of California (the FTB) released a proposed regulation — new section 17951-8 of Title 18 of the California Code of Regulations — which treats the compensation of a California nonresident, non-employee director of a corporation as California-source income subject to California personal income…