News & Analysis as of

Corporate Taxes

UK Tax Round Up - July 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Conservative legislative agenda set out in Queen's Speech - Following the UK general election on 8 June 2017, at which the Conservative party won the largest number of seats but lost its...more

Tax Court Rejects IRS’ Position in Rev. Rul. 91-32

Grecian Magnesite Mining, a Greek corporation (GMM), owned an interest in Premier Chemicals LLC, a Delaware limited liability company classified as a partnership for US income tax purposes (Premier). Premier conducted a trade...more

Polish Ministry of Finance publishes a draft bill proposing significant changes to corporate income tax

by DLA Piper on

The Polish Ministry of Finance has published a draft bill that proposes significant changes to, among other things, the Act on Corporate Income Tax (Bill). Its aim is to close loopholes in the corporate tax system. The Bill...more

Getting Something for Nothing: IRS Withdraws Proposed “Net Value” Regulations

In June 2005, the Internal Revenue Service (IRS) issued a package of proposed regulations providing that certain corporate liquidations, formations and reorganizations would not qualify for nonrecognition treatment if the...more

Corporate Inversions

by Kelley Drye & Warren LLP on

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

State Tax Update for Delaware Corporations

by Dechert LLP on

While the State of Delaware has numerous attractive aspects for entities that incorporate there (a flexible corporation statute, the well-respected Court of Chancery, a legislature that prioritizes the stability of Delaware’s...more

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

Q&A with Sheppard F. Miers: Federal tax reform could affect state tax determinations

by GableGotwals on

Q: Would tax reform at the federal level affect the taxes we pay at the state level? A: Oklahoma state income tax generally conforms to the federal income tax imposed under the Internal Revenue Code. In general, income and...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Entity Selection Series | Part Three: The Benefits of an S-Corporation

In Part One and Part Two of the Entity Selection Series, we discussed the benefits of a Limited Liability Company and a C-Corporation for organizing a venture business. In this edition, we will discuss the benefits (and...more

IRS Identifies 8 Burdensome Regulations for Reform

Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more

Minority Shareholders’ Derivative Suit Foiled by Voiding of Corporation’s Charter for Nonpayment of Taxes

by Farrell Fritz, P.C. on

A business’s failure to pay state taxes can be a problem if the entity later wants to bring a lawsuit, or its non-controlling owners want to sue on the entity’s behalf....more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

Tax Legislation Enacted During the Regular Session of the 2017 North Carolina General Assembly

by Smith Anderson on

A previous Tax Alert (June 20, 2017) summarized the tax provisions in the North Carolina 2017 budget bill (the Appropriations Act of 2017) as passed by the General Assembly. The Governor later vetoed the budget bill, but the...more

Downstream Reorganizations

by Alston & Bird on

LTR 201721014 ruled that a holding company can reorganize into a partly owned subsidiary by swapping old shares for new shares of the subsidiary and then liquidating. The technique is an old one, but tends to be forgotten...more

Tax Savings in the United States Virgin Islands – the Basics

by Garvey Schubert Barer on

When many people think of the United States Virgin Islands (“USVI”), they think of beautiful beaches on secluded islands. This is certainly correct, but many people do not know that the USVI is also home to some of the most...more

The UK Double Tax Treaty Passport Scheme – Changes for the UK Loan Market

by Morrison & Foerster LLP on

The UK Double Tax Treaty Passport (“DTTP”) scheme has recently been extended by HM Revenue & Customs (“HMRC”) to allow both non-corporate borrowers and lenders to enjoy the benefits of the scheme. The aim of the amendments is...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Trends in cross-border real estate investment and the changing tax landscape

by Hogan Lovells on

Real estate markets in both the U.S. and Europe continue to attract significant overseas investment. With interest rates at or near all-time lows, and dwindling returns in other asset classes, real estate has emerged as...more

The Oregon Corporate Gross Receipts May Be Dead – at Least for Now

by Garvey Schubert Barer on

For more than a year, I have been discussing the potential that Oregon lawmakers will pass a corporate gross receipts tax. On May 26, 2017, we discussed recent events that would lead a reasonable person to believe that the...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

The Taxpayer Transparency And Fairness Act Is Anything But

by Allen Matkins on

Recently, I wrote about the stealth with which the California legislature enacted AB 102, which it ironically named the Taxpayer Transparency and Fairness Act of 2017. Having been birthed in opacity, AB 102 will operate with...more

The Scambler Case: Tax Law in Plain English?

A recent decision of the Upper Tribunal (Tax and Chancery Chamber) (UT) in Scambler and another v HMRC [2017] UKUT 1 (TCC) considers the question of when it is appropriate to look back to earlier versions of tax legislation...more

Tax Provisions in the 2017 Budget Bill

by Smith Anderson on

The General Assembly released today the Proposed Conference Committee Substitute (the “Conference Bill”) for Senate Bill 257, the state budget bill. The Conference Bill is expected to be approved by the General Assembly later...more

The Taxpayer Transparency and Fairness Act of 2017 – A Little Bill May Soon Make Big Changes

by Allen Matkins on

The talk of California tax practitioners over the last week has been all about the legislature’s passage of AB 102. This may be surprising to those who read the bill when it was introduced on January 10 of this year, for the...more

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