Evan Migdail

Evan Migdail

DLA Piper

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The Trump tax reform plan – key points

As a result of the elections, the chances for the enactment of comprehensive tax reform are perhaps greater than at any time over the past decade. A great deal of work has already been done on tax reform in the Congress. What...more

11/11/2016 - Corporate Taxes Donald Trump Legislative Agendas Tax Reform

PROMESA becomes law: all businesses in Puerto Rico will be affected – top points about this sweeping rescue package

Just one day before the July 1 deadline for an expected major default by the Government of Puerto Rico, President Barack Obama signed into law the Puerto Rico Oversight, Management and Economic Stability Act (PROMESA), a...more

7/5/2016 - Barack Obama Financial Crisis Popular Puerto Rico Puerto Rico Oversight Management and Economic Stability Act (PROMESA)

Global Tax News: US Treasury's proposed §385 regulations under extreme scrutiny on Capitol Hill, in corporate tax departments: top...

As part of its ongoing effort to try to curb inversion transactions, the Treasury Department has issued proposed regulations under section 385. Section 385(a) authorizes the Treasury Department to issue regulations that may...more

5/23/2016 - Bifurcation Corporate Taxes Inversion IRS Proposed Regulation U.S. Treasury

Global Tax News - February 2016

The European Commission has released its highly anticipated anti-tax-avoidance package. The package, released January 28, 2016, contains proposed rules and recommendations to avoid aggressive tax planning within the...more

2/8/2016 - Audits BEPS Brazil Canada Currency Exchange Estate Tax EU European Commission FIRPTA International Tax Issues IP License Russia Software Tax Avoidance Tax Reform UK VAT

FIRPTA reform under the Protecting Americans from Tax Hikes Act of 2015: key points for non-US investors

Among the reforms and provisions in the Protecting Americans From Tax Hikes Act of 2015 are several important changes to the Foreign Investment in Real Property Tax Act of 1980 (commonly referred to as FIRPTA) that are...more

2/5/2016 - FIRPTA Investors Pension Funds Protecting Americans from Tax Hikes (PATH) Act REIT

Tax Reform Alert (US): Chairman Brady's Vision for US Tax Reform in 2016 and 2017

In various forums over the past few days, House Ways and Means Committee Chairman Kevin Brady (R-TX) has discussed his tax priorities over the coming year and his vision and timing generally for tax reform. In Brady’s view,...more

1/14/2016 - Congressional Committees Fixing America’s Surface Transportation Act (FAST Act) Tax Reform

Global Tax News: US Congress: tax reform emerging as major 2016 campaign issue – financial industry a prime target

Tax reform is emerging as a major issue in the 2016 US presidential campaign, and in the growing wave of populist anger at the establishment elite in Washington and Wall Street, the financial industry has become a prime...more

9/30/2015 - Carried Interest Congressional Committees Corporate Taxes Financial Institutions Hedge Funds Income Taxes Legislative Agendas Political Candidates Presidential Elections Private Equity Real Estate Investments Tax Reform Tax-Deferred Exchanges

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

6/13/2015 - Competition Corporate Taxes Highway Trust Fund Innovation Innovation Patent International Tax Issues Legislative Agendas Popular Tax Incentives Tax Reform The Patent Box

Patent box concept emerges on the tax reform agenda for US Congress

Key tax writers in Congress are indicating that once Congress disposes of pending trade legislation, they will turn to their top legislative priority: reaching a consensus on international and business reform by the end of...more

5/28/2015 - Business Taxes Congressional Investigations & Hearings Corporate Taxes Innovation International Tax Issues Legislative Agendas Popular Tax Incentives Tax Reform The Patent Box

Congressional leaders set a deadline for tax reform: key elements in the top proposals

Just prior to leaving Washington for official travel at the end of last week, House Ways and Means Committee Chairman Paul Ryan (R-WI) told reporters that he is in constant touch with Treasury Secretary Jack Lew with respect...more

2/20/2015

Potential roadmap to US tax reform: key points in the Hatch Report

As the work of the new Congress gets under way , there is general agreement that business tax reform is one of a handful of issues that may be achievable in the closing two years of the Obama Administration, and, in fact,...more

1/23/2015 - Corporate Taxes Legislative Agendas Legislative Committees Tax Reform

Congress passes tax extenders – through the end of 2014: potential impact on tax reform

In the final act of the 113th Congress, the Senate passed and sent to President Barack Obama for his signature the Tax Increase Prevention Act of 2014, extending through the end of 2014 numerous familiar deduction and credit...more

12/18/2014 - Tax Extenders Tax Reform

International Tax News - December 2014

UK WILL IMPOSE CAPITAL GAINS TAX ON NON-UK RESIDENTS - The UK government aims to go ahead with plans to impose capital gains tax on sales of residential property from April 2015. The government has published...more

12/16/2014 - Capital Gains Corporate Taxes Income Taxes UK

Tax reform after the mid-terms: why we can expect Congress to act

While some aspects of the agenda for the incoming Republican-controlled 114th Congress are still in formulation, there is no question that tax reform will be a top priority. Both the expected new Senate Majority Leader Mitch...more

11/7/2014 - Election Results Legislative Agendas Tax Reform

International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

9/25/2014 - BEPS Corporate Taxes G20 Income Taxes International Tax Issues Multinationals Tax Evasion

New Treasury rulemaking aims to curb advantages of inversion - will this affect your deal?

Yesterday, following a summer during which a number of major American companies announced plans to invert (i.e., shift their tax domiciles overseas following cross-border mergers), the US Treasury Department issued a notice...more

9/24/2014 - Corporate Taxes Cross-Border Domicile International Tax Issues Inversion Mergers

Major changes ahead as Congress takes on the highway trust fund crisis – and looks to comprehensive tax reform

Over the next two weeks as Congress prepares for its long summer recess, major decisions will be made affecting the legislative tax agenda for the rest of this session of Congress and, in the case of tax reform, for...more

7/16/2014 - Highways Infrastructure Legislative Agendas Legislative Committees Public Projects Tax Reform

The Camp US tax reform proposal: what’s inside?

House Ways and Means Committee Chairman Dave Camp (R-Michigan) this week introduced a draft of the most comprehensive reform of the Internal Revenue Code in decades. The key principles in the draft are: (1) a...more

3/3/2014 - Charitable Donations Energy Tax Incentives Income Taxes Tax Deductions Tax Reform

Camp unveils major tax reform plan

Yesterday, House Ways and Means Committee Chairman Dave Camp (R-Michigan) unveiled his comprehensive tax reform proposal. Released as draft legislation, the Camp proposal calls for the most fundamental reform of the tax code...more

2/27/2014 - Corporate Taxes Income Taxes International Tax Issues Tax Reform

Camp proposal – most fundamental tax reform in nearly 30 years: coming soon

House Ways and Means Committee Chairman Dave Camp (R-MI) is on the verge of releasing a detailed proposal for comprehensive tax reform. The Camp proposal, which may be released in the form of a discussion draft and...more

2/20/2014 - Flat Tax Tax Reform

In the tax reform crosshairs: the advertising deduction

The tax deduction for advertising expenses has clearly become a target for Congressional tax reformers. Under current law, advertising costs are fully deductible as an ordinary business expense. Both the House and Senate Tax...more

12/5/2013 - Advertising Proposed Legislation Tax Deductions Tax Reform

Multinationals take note: Baucus releases US international tax reform proposal, welcomes stakeholder comments

Senate Finance Committee Chairman Max Baucus (D-Montana) has released the first of a coming series of detailed tax reform proposals, this one on international tax. Today, Baucus also released proposals on tax...more

11/21/2013 - Income Taxes Multinationals Shareholders Tax Reform U.S. Treasury

Is Congress postponing the tax reform debate?

Although the chairmen of the tax writing committees, Representative Dave Camp (R-Michigan) and Senator Max Baucus (D-Montana), are thoroughly committed to enacting comprehensive tax reform and are devoting the considerable...more

11/18/2013 - Proposed Legislation Tax Reform Ways and Means Committee

Congressional budget talks – an opportunity to advance tax reform?

Taxes will be a major part of the budget discussions now under way in Washington. Is this an opening for comprehensive reform? Earlier this year, the House and Senate passed very different proposals for the federal...more

10/22/2013 - Debt Ceiling Federal Budget Political Debates Tax Reform

Events moving fast in Congress: the shape of things to come?

The next two days in Congress will be characterized by fast-moving developments on the government shutdown/debt ceiling issues. As of this morning the situation is as follows...more

10/16/2013 - Affordable Care Act Debt Ceiling Federal Budget Government Shutdown

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