Corporate Taxes

News & Analysis as of

Is it Debt or is it Not? Proposed Treasury Regulations Would Significantly Change Debt vs. Equity Analysis

Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more

Mississippi Legislature Passes Significant Tax Relief

On April 18, 2016, the Mississippi Legislature passed Senate Bill 2858 and enacted the “Taxpayer Pay Raise Act of 2016.” Lieutenant Governor Tate Reeves describes the Act as the largest tax relief package in Mississippi...more

Tax Review - April 2016

We are proud to present the next edition of our Tax Review which contains a selection of rulings and interpretations that were issued or published in March 2016. We hope that you will find in it information that may prove...more

"FIRPTA Reform Impacts Investment Opportunities in US Real Estate"

In recent months, much has been written to describe the reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) contained in the Protecting Americans From Tax Hikes Act of 2015 (the Act), which have been...more

Tax Newsletter - January / February 2016 (China & Hong Kong)

Welcome to the latest issue of our Tax newsletter. In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC,...more

China's Nationwide VAT Reform - Implementation Rules Issued

In this issue, we have covered a number of developments and cases in the PRC and Hong Kong which could impose legal and tax implications to your business. In the PRC, there has been an important development in the past...more

Federal Court of Appeal Clarifies Test for “De Facto Control”

In McGillivray Restaurant Ltd. v. R., the Federal Court of Appeal (FCA) recently provided welcome news to the Canadian tax community concerning the appropriate legal test for determining whether a person has “de facto...more

Is Your Corporation “Zeroing Out” Income at End of Year Through Bonuses? Watch Out!

For the last few years the IRS has warned taxpayers that it would look closely at year-end bonuses that resulted in “zeroing out” taxable income of a corporation by deducting the bonuses as salary rather than a payment of...more

Singapore budget 2016

The Singapore Budget Statement 2016 (“Budget 2016”), delivered by Finance Minister Heng Swee Keat on 24 March 2016, has been described as balanced and transformative, focusing on both medium to long term restructuring (such...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Proposed IRS and Treasury Regulations Have Broad Implications for Intercompany Debt Structures

On April 4, 2016, the U.S. Treasury Department and the Internal Revenue Service (“IRS”) issued proposed regulations ostensibly aimed at curbing inversions and earnings stripping, by companies located in the U.S. with overseas...more

China Customs authorities enhance monitoring of intercompany prices and royalty payments

China’s General Administration of Customs (GAC) has released an amendment to the Import and Export Declaration Documents Standards. Among many changes, the Amendment now requires Chinese entities with importing and exporting...more

Latest Treasury Action on Inversions Upends Pending Transactions and Surprises Many for Its Broad Scope and Use of Questionable...

On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions (the “Regulations”). Many features of the Regulations had...more

Corporate Tax Reform Proposal Would Raise Taxes on Exempts

Legislation could impose new taxes on dividend and interest income of tax-exempt entities. The Senate Finance Committee is reportedly formulating a legislative proposal to integrate the corporate and individual tax...more

International Tax Advisory: New Temporary Regulations Continue the Fight Against Inversions

On April 4, the Treasury released temporary regulations to attack (and prevent) inversions. Aimed at transactions designed to avoid the purposes of Sections 7874 and 367 and certain post-inversion avoidance transactions, the...more

Cayman Islands FATCA/CRS Compliance Deadlines (2016)

Cayman Islands investment entities are currently subject to three separate regimes relating to financial account information reporting: U.S. FATCA, U.K. FATCA and the OECD Common Reporting Standard (CRS). Although these...more

Treasury Department Issues Temporary and Proposed Regulations to Curb Inversions and Earnings Stripping

On April 4, 2016, the Internal Revenue Service and the Treasury Department issued temporary and proposed regulations formalizing rules contained in Notices 2014-52 and 2015-79 limiting corporate tax inversions, as well as...more

Three Important Alabama Regulatory Developments

Last month, the ADOR proposed a new rule, Rule 810-3-35-.01, in order to simplify the federal income tax deduction available to corporations doing business in Alabama. The ADOR proposed to repeal the current corporate federal...more

MTC Arm’s-Length Adjustment Service (Part II): “An Expression of Grief, Pity, or Concern”

Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more

New Guidance Rewrites Debt/Equity Rules and Further Limits Inversions

The IRS and Treasury Department released a package of temporary and proposed regulations on April 4, 2016 ostensibly aimed at further curbing corporate “inversion” transactions. The regulations cover a wide range of tax...more

New Regulations Issued to Expand the Reach of Anti-Inversion Rules

Code Section 7874 seeks to remove the U.S. tax benefits that can apply by inserting a non-U.S. holding company into the ownership structure of businesses formerly conducted through a U.S. holding company. This is a big...more

Development of the tax practice of the “beneficial owner” concept

On March 3, 2016 the Commercial Court of Moscow rendered a decision on case No. ?40-241361/15 (the “Decision”) under the claim of BANK INTEZA joint stock company (the “Russian Company”). The decision contains a number of...more

UK Corporate Briefing Spring 2016 - Issue 5 - Spring 2016

Welcome to the spring 2016 edition of Dentons' UK Corporate Briefing, a quarterly summary of the most significant recent and forthcoming developments in company law and corporate finance regulation in the UK. Please see...more

Tax Review - March 2016

We are proud to present the next edition of our Tax Review which contains a selection of rulings and interpretations that were issued or published in January and February 2016. We hope that you will find in it information...more

Proposed Regulations Would Fundamentally Change Treatment of Intra-Group Debt Transactions

On April 4, 2016, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued two sets of regulations, temporary regulations addressing “inversion” transactions and proposed regulations regarding the...more

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