Corporate Taxes

News & Analysis as of

Tax Reform in 2017? What is in Store for U.S. Businesses

With Republicans in control of the White House and Congress, one of the top priorities is tax reform. President Trump’s tax reform proposal and the House Republicans’ tax reform “Blueprint” suggest many changes to business...more

Trump Administrations Agenda affects Wealth Management

There’s little doubt that President Trump will carry through on the many promises that he made during the campaign that affect individuals, investors and advisors in the Wealth Management Industry. Corporations, too, were...more

US: Proposed "Border Adjustment Tax” could kill foreign IP holding companies

With President Trump in the White House and a Republican majority in both the House and Senate, tax reform is once again high on the agenda. Several weeks ago, President Trump promised “a tax reform bill that will reduce our...more

Trump Promises Tax Reform Announcement in the Next Few Weeks

President Trump recently indicated that he will announce a tax reform proposal within the next two to three weeks. The existing tax proposals from President Trump and the Congressional Republicans are predictably vague at...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Tax Planning in Uncertain Times

There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the...more

The Trump Administration – Part IV: The Business Response

This week I have been considering the first few weeks of the Trump administration from the business perspective. It has certainly been a chaotic start, with a raft of announcements, Executive Orders and social media postings...more

Is Your Customs Compliance BEPS Ready?

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

"Trump’s Proposed Changes to Tax, Dodd-Frank, DOL Could Impact Executive Compensation"

President Donald Trump’s campaign proposals included changes to tax rates and a promise to repeal the Dodd-Frank Act. If enacted, these proposals could have a significant impact on the way businesses handle executive...more

Tax Code of Ukraine: 2017 edition

In 2017 a set of changes and amendments have been introduced into the Tax Code of Ukraine (Tax Code) based on the adoption of the two draft laws: Draft law No.5368 on improvement of the investment climate in Ukraine and Draft...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Shareholder Liability For Corporate Income Tax?

Limited Liability - In general, the creditors of a corporation cannot recover the corporation’s debts from its shareholders—the shareholders enjoy the benefit of limited liability protection as a matter of state law....more

IRS Issues New Guidance on TIGER Grants

In Revenue Procedure 2017-22, the IRS clarified earlier guidance regarding safe harbors for corporate taxpayers receiving grants from the government for capital improvements to transportation services. Section 118...more

House Proposal for Border Adjustability and Relevant WTO Rules

On June 24, 2016, on behalf of the House Republican Caucus, House Speaker Paul Ryan, R -Wis., and House Ways and Means Chairman Kevin Brady, R -Tx., proposed sweeping reforms of the U .S. income and corporate taxes. The...more

Doing Business in the UAE

Country Background - Formed on 2 December 1971, the UAE is a federal state of seven emirates comprising Abu Dhabi, Ajman, Dubai, Fujairah, Ras Al Khaimah, Sharjah and Umm Al Quwain. The UAE federal constitution...more

Client Alert: State Supreme Court Decision Creates Limited Tax Refund Opportunities

Taxpayers who filed as, or were included as a member of, a unitary business group could qualify for a refund following a decision by the Michigan Court of Appeals that the Michigan Supreme Court chose to let stand on January...more

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. ?11-6602/2016 (the “Decision”) under the claim of Vladimir Energy RetailCompany1 Public Joint-Stock Company (the “Company”)....more

"Volatility and Uncertainty Continue in the US Capital Markets"

The U.S. capital markets experienced continued volatility throughout much of 2016, as the bond and equity markets were affected by a series of significant events: the November U.S. presidential election; the June Brexit vote;...more

"Mergers and Acquisitions: 2016 Update"

Global mergers and acquisitions volume in 2016 declined from the record levels set in 2015, but activity was nonetheless strong by historical standards. Value of global deals was approximately $3.7 trillion, an annual total...more

Ryan Says Tax Reform Coming, But Later This Year

On Friday, House Speaker Ryan stated publicly that tax reform legislation will be included in one of two must pass budget resolutions this year, but it will be included in the fiscal 2018 budget resolution rather than in the...more

Alberta Investor Tax Credit: Alberta introduces a new investor tax credit aimed at small business

On January 16, 2017, the online application portal for the Alberta Investor Tax Credit (AITC) opened to Alberta small businesses seeking to benefit from the recently introduced AITC and it will remain open until the 2017...more

UK Tax: When Partnership Is Not Partnership

The recent decision of the First Tier Tribunal (FTT) in the unusual case of R. Ashton v HMRC [2016] UKFTT 727 serves as a useful reminder to taxpayers of two issues: (1) the potential for confusion when distinguishing between...more

China Tax Newsletter - September / December 2016

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 from September to December 2016 which could have legal and tax implications to your...more

Transmission Partnership Not Deemed Includible in Consolidated Return and Allowed To Collect Income Tax Allowance in its Rates

On January 6, 2017, Texas utility companies organized as pass-through entities, including partnerships, received welcome news regarding their ability (1) not to elect to be treated as a corporation eligible to be included in...more

BEPS: Update on Action 6 on Treaty Benefits

In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and...more

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