• Deferred taxes on offshore fund incentive fees may not be dead after all

    In the recently published Revenue Ruling 2014-18, the Internal Revenue Service (IRS) concluded that certain nonqualified stock options (NSOs) or stock appreciation rights (SARs) would not be subject to the anti-deferral rules of Internal Revenue Code section 457A (section 457A). Generally, section 457A prohibits the deferral of income for service providers that perform services for nonqualified entities (i.e., foreign corporations based in offshore tax havens, entities substantially owned by tax-exempt organizations, or other tax-indifferent parties).
  • Dos and don’ts when doing business in China

    Despite the economic developments in major parts of the country, and modern Chinese people’s increasing appetite on adopting western styles of living, China is still a country with a very special character of its own. Insight in Chinese traditions and habits and careful preparations prior to any important meetings are essential, even for the experienced executive.