News & Analysis as of

Corporate Taxes

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

Business Tax Reform – the Current State of Play

by Ballard Spahr LLP on

President Donald J. Trump campaigned on a platform of large tax cuts for businesses. With President Trump in the White House and Republicans controlling both the House of Representatives and Senate, does it mean businesses...more

Dutch Supreme Court refers questions on withholding tax refunds for foreign investment funds to CJEU

by DLA Piper on

The Dutch Supreme Court has referred preliminary questions on Dutch dividend withholding tax refunds for foreign investment funds to the Court of Justice of the European Union (CJEU). The Dutch Supreme Court wishes to clarify...more

CA Court of Appeal’s Split Decision Upholds CARB Cap-and-Trade Program

by Perkins Coie on

In a 2-1 decision, the California Court of Appeal, Third Appellate District, upheld the California Air Resource Board’s cap-and-trade program for greenhouse gas allowances. California Chamber of Commerce v. State Air...more

2017 commercial real estate outlook: The impact of U.S. tax reform - April 2017

by Hogan Lovells on

Despite strengthening market headwinds and troubling political uncertainties, the U.S. commercial real estate market is likely to remain the top destination for global real estate capital in 2017, and may even see a return to...more

China Tax Newsletter - January / February 2017

by DLA Piper on

Welcome to the latest issue of our Tax Newsletter. In the past two months, there are a number of developments in the tax world in the PRC and Hong Kong. In the PRC, the State Administration for Industry and Commerce...more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part II

by Farrell Fritz, P.C. on

Aside from planning for the taxation of U.S.-sourced rental income, the foreigner must plan for the disposition of the USRP pursuant to a sale. The taxation of gain realized by a foreigner on the sale of an interest in...more

Trump Tax Reform: Tax Policy Outlook

by Polsinelli on

Comprehensive tax reform that lowers business and individual tax rates, streamlines the tax code, and allows U.S. businesses to become more competitive in the global economy are among the top priorities of the Trump...more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part I

by Farrell Fritz, P.C. on

Over the last few years, we have received an ever-increasing number of inquiries from “foreigners” who are interested in acquiring U.S. real property (“USRP”). Some of these foreigners – meaning closely-held business...more

Prepared for the Border Adjustment Tax? A U.S. and Global Perspective

by K&L Gates LLP on

K&L Gates' Global Tax Group has been monitoring the potential impact of the Border Adjustment Tax (BAT) across a number of jurisdictions. In our 14 February 2017 update, we commented that issues regarding the legality of...more

Discharge of Federal and State Income Taxes in Bankruptcy

by McNair Law Firm, P.A. on

If an individual or business owes unpaid income taxes to the IRS, or to a state, federal bankruptcy laws may provide relief for some, if not all, of these taxes. Generally applicable to “older” federal and state income taxes,...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Australian Government proposes to increase access to tax losses through the introduction of the similar business test

by DLA Piper on

On 30 March 2017, the Federal Government released the Treasury Laws Amendment (2017 Enterprise Incentives No 1) Bill 2017. The Bill introduces the "similar business test" to supplement the existing "same business test"....more

Locke Lord Article: Tracking Tax Reform

by Locke Lord LLP on

With the recent release and subsequent quick defeat of the American Health Care Act (AHCA), healthcare reform dominated the news and tax reform was waiting for its turn in the spotlight. Tax reform was a major issue on the...more

Further Update on Federal Taxation - Australian Infrastructure Investment and Privatisation

by Jones Day on

Last month, we reported in our White Paper on taxation proposals directed at infrastructure and utility privatisation transactions. Since we wrote, the Commonwealth Treasury ("Treasury") has published a policy paper directed...more

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

Beltway Briefing: Special Tax Policy Briefing

by Cozen O'Connor on

Blake Rutherford and Howard Schweitzer of Cozen O'Connor Public Strategies analyze the future of tax reform and the implications on the business community. Blake: Today for this special briefing on tax reform, which is...more

Unpacking Your LLC: Tax Considerations in Limited Liability Company Liquidations

by Smith Anderson on

Has your LLC lost its luster? Has it outlived its usefulness as an asset management, asset protection, or, dare we say it, wealth transfer vehicle? Are you tired of discussing the company’s operations with the other owners?...more

Financial Services Quarterly Report - First Quarter 2017: Luxembourg Parliament Adopts 2017 Tax Reform Measures

by Dechert LLP on

The Luxembourg Parliament has adopted new tax measures that affect individual and corporate taxpayers, with effect from 1 January 2017.1 This article summarizes key measures....more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

New UK Tax Relief Restrictions for Corporate Interest

by Reed Smith on

This briefing provides a high-level summary of the new rules limiting the UK tax deductibility of corporate interest expenses. The new rules apply from 1 April 2017 to interest payments made from that date under new and...more

2017 Federal Budget measures affecting the energy industry

by DLA Piper on

There are several measures in this year’s Canadian Federal Budget that directly affect the energy industry. This is a highlight of these proposed changes....more

EuroResource—Deals & Debt - March 2017

by Jones Day on

For the benefit of our clients and friends investing in European distressed opportunities, our European Network is sharing some current developments...more

Net Operating Loss Carryforwards on President Trump’s 2005 Income Tax Return

James B. Stewart, writing for The New York Times (March 23, 2017), explored the complexities of President Donald Trump’s 2005 U.S. income tax return, which was revealed publicly last week. President Trump used $103 million...more

Michigan Treasury Issues Revised Interpretation of Unitary Business Groups Following LaBelle Decision

by Varnum LLP on

On February 28, 2017, the Michigan Department of Treasury issued guidance in response to the Supreme Court's denial of Treasury's application to appeal LaBelle Management, Inc v Michigan Department of Treasury, 315 Mich App...more

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