The insertion of a US holding company by way of a share-for-share exchange, whereby the shares in an existing UK company (“UKCo”) are transferred to a new US company (“USCo”) in exchange for shares issued by USCo, is commonly...more
Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more
2/2/2018
/ Bonus Depreciation ,
Carried Interest Tax Rates ,
Compensation & Benefits ,
Corporate Taxes ,
EBITDA ,
Executive Compensation ,
Income Taxes ,
Net Operating Losses ,
New Legislation ,
Partnership Interests ,
Pass-Through Entities ,
Portfolio Companies ,
Private Equity Funds ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more
12/29/2017
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Tax Credits ,
Income Taxes ,
International Tax Issues ,
Legitimate Business Interest ,
New Legislation ,
Pass-Through Entities ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Deferral ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act (“H.R. 1”), and later proposed amendments to the bill on November 3, November 6, and...more
11/13/2017
/ Business Taxes ,
Capital Contributions ,
Corporate Taxes ,
Cross-Border Transactions ,
Excise Tax ,
Financial Transactions ,
Legislative Agendas ,
Legitimate Business Interest ,
Mortgage Interest ,
Pass-Through Entities ,
Proposed Legislation ,
REIT ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Paris administrative court ruled on July 12th, 2017, that Google Ireland Limited did not have to pay $1.3 billion in back taxes in France for the period 2005-2010.
The Irish company Google Ireland Limited sells digital...more
9/12/2017
/ BEPS ,
Corporate Taxes ,
Double Taxation ,
France ,
Google ,
Income Taxes ,
Ireland ,
Multilateral Agreement ,
OECD ,
Tax Treaty ,
Value-Added Tax (VAT) ,
Withholding Tax
On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime (the "Act"), most notably for out-of-state corporations providing digital products to New...more