Corporate Taxes

News & Analysis as of

The Qualified Subchapter S Subsidiary Election – A Primer and Beyond

Mr. Brant’s article offers readers a broad overview of the QSub election and a review of the history surrounding its statutory creation. In addition, it provides a rather in-depth discussion of the QSub qualification...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Kübler-Ross and IRS Announcement 2016-32

When the IRS announced that it would virtually eliminate the determination letter program for individually designed retirement plans, many practitioners moved through the classic Kübler-Ross five stages of grief. Some have...more

Changes to Dutch dividend withholding tax rules

Today, the Dutch Ministry of Finance announced that it intends to introduce two important changes to the Dutch dividend withholding tax rules...more

Focus on Tax Controversy and Litigation - The Unprecedented Extraterritorialization of Tax Crimes

In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s...more

Digesting the €13 Billion Apple-EU Tax Ruling

King & Spalding experts assess what international businesses need to be aware of following the EC's ruling on State Aid in the Apple case - Partners in King & Spalding’s tax department have shared their perspectives and...more

10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements

As the European Commission reviews whether tax arrangements conform with State aid rules, companies active in Europe should ensure their fiscal regimes comply with EU law. In recent years, the European Commission (the...more

Tax Alert for Foreign Investors Looking at U.S. Investments

Pre-immigration and Non-U.S. Resident Planning - It does not matter whether foreign individuals are investing in U.S. property and hoping to become residents in the U.S., or are planning to invest in U.S property...more

Overview of Luxembourg Tax Developments - September 2016 - Issue 01

This report summarizes some of the main Luxembourg tax developments that took place between the end of 2015 and August 2016. The selected developments are mainly relevant to companies and the international tax...more

Doing Business in Australia

With 25 years of uninterrupted GDP growth, a robust regulatory environment and diverse, globally competitive industries, Australia remains an exceptional place to do business. As the fourth largest economy in the...more

MoFo New York Tax Insights - Volume 7, Issue 9

Appellate Division Holds That NYS Tax Department Properly Withheld Documents Requested Under FOIL - In a unanimous decision, the Appellate Division affirmed a decision of the Supreme Court, Albany County, which had...more

Amendments of CIT and PIT Acts in Poland

On 5 September 2016, the lower chamber of the Polish parliament (Sejm) accepted changes made by the Senate to the Act amending PIT and CIT. The Amendment Act has been sent to the President for signing....more

State aid – the European Commission charges forward

This note provides an update on the EU state aid decisions and aims to put recent developments in context. We review the current state of the state aid investigations, provide some political context, touch on the US...more

The Tax Man Cometh To Nevada Businesses

Nevada likes to market itself as a low tax jurisdiction, touting the fact that “Nevada does not impose income tax on domestic or foreign corporations.” It may not impose a tax on income, but it does impose a tax on...more

Preparing for a Washington State Department of Revenue Audit

The Washington State Department of Revenue (“DOR”) is the enforcement agency for the state sales, business and occupation (“B&O”), and other excise taxes. The DOR conducts routine excise tax audits through its Audit...more

Did You Know That Payroll Taxes Non-Compliance Can Get You Into TROUBLE?

S Corps are corporate entities through which the income and or losses of the entity pass through to its owner’s personal income tax return. It is estimated that 100% of the shares of approximately 70% of small businesses...more

Implications of the UK’s Brexit Referendum

As autumn approaches and preparation for the next round of Brexit discussions begins, this note summarises the current position and analysis following the UK’s vote to leave the EU on the 23rd June (the “Referendum”). Whilst...more

EU tax ruling levies €13 billion state aid penalty on Apple

On 30 August 2016, Ireland was ordered by the EC to recover up to €13 billion from Apple on the basis that tax arrangements implemented between Apple and Ireland, originally in 1991, amounted to the provision of unlawful tax...more

The sukuk experience in Turkey

Turkey's government is determined to make Istanbul a financial hub for Islamic finance, regionally and globally. With a GDP of US$733.6 billion in 2015 according to the IMF, Turkey is the 18th largest economy in the world,...more

Battle Heats Up Over Who Can Regulate Tax on International Companies

In a decision that again pits the United States against the European Union in that ongoing battle over which entity can primarily tax international business, Margrethe Vestager, the European Union commissioner for...more

China Tax Newsletter - May / June 2016

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. On the PRC side, following the national rollout of the...more

Maryland Tax Court Overturns Comptroller's Policy of Limiting Subtraction for Interest Received on Federal Obligations

The Maryland Tax Court recently ruled that a bank was entitled to deduct all of its interest received with respect to federal obligations for Maryland corporate income tax purposes, thereby generating net operating losses...more

Is an S Election for an LLC Smart Planning or a Bad Idea?

By default, a limited liability company (“LLC”) with two or more members is taxed as a partnership. It also is possible to elect to treat an LLC as an S corporation for income tax purposes. But is it a good idea? And if an S...more

Proposed Treasury Regulations To Affect Family Wealth Transfers

On August 2, 2016 the U.S. Treasury Department issued proposed regulations addressing transfers between family members of interests in family-controlled entities (e.g., corporations, partnerships and LLCs). If enacted, these...more

Dubai Airport Freezone Authority

Dubai Airport Freezone (DAFZA) is one of the region’s fastest growing Freezones. Established in 1996, DAFZA is home to over 1,450 companies, covering a range of key industry sectors, including aviation, freight & logistics,...more

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