Articles
Holding Companies: Modifications in the IRAE for Passive Income from Abroad
One of the main changes refers to passive income, which would now be taxed by IRAE if they did not meet certain conditions established in the regulations, and which is of special interest for holding companies.
Taxing Crypto-Assets
Indemnity Caps
This article examines how buyers and sellers are negotiating indemnity caps in private company M&A transactions, as shown in the American Bar Association’s (ABA) private target deal points studies.
After-Tax Indemnity Limitations
In merger and acquisition transactions, the definitive purchase agreement, whether asset purchase agreement, stock purchase agreement, or merger agreement, typically contains representations, warranties, and covenants, along with related indemnification obligations.
The Illegal Granting of Credit or the Dilemma of the Good Banker
In the course of 2021, the Supreme Court reached a significant milestone in the systematic elaboration and reconstruction of the liability of the Bank for abusive granting of credit.