News & Analysis as of

Corporate Taxes

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

German Constitutional Court Declares Parts of Provisions Regarding Forfeiture of Tax Losses and Loss Carry Forwards...

by Shearman & Sterling LLP on

The German Constitutional Court held in its decision dated 29 March 2017 (published on 12 May 2017) Section 8c sentence 1 German Corporate Income Tax Act (KStG) (introduced in 2008 and replaced by the identical provision of...more

Federal Tax Reform and the Oklahoma Income Tax

by GableGotwals on

Tax reform is being proposed in Congress and by President Trump to make major changes to the federal income tax imposed under the Internal Revenue Code. Oklahoma imposes a state income tax on individuals, corporations, and...more

Trump’s Tax Reform Plan – When the Dessert Pays for Dinner

by Alston & Bird on

Doubling down on his promise to achieve monumental tax reform, President Trump on April 26 issued a tax reform plan outlining his Administration’s broad aims. Once again, he has made it clear that large-scale tax reform is a...more

Federal Tax Reform Legislation in 2017: Comments by Attorney Morris N. Robinson

Attorney Morris N. Robinson, the Managing Director of M. Robinson Tax Law in Boston, recently published an op-ed titled: Viewpoint: A 15 percent tax rate on business would maximize economic growth....more

Trump Administration Proposes Significant Tax Overhaul

by Baker Donelson on

On April 26, Treasury Secretary Steven Mnuchin and Gary Cohn, director of the National Economic Council, presented the Trump Administration's tax reform proposal to the media. The proposal consisted of a one-page outline that...more

Development of court practice of determining the starting date for payment of property tax on a fixed asset that is ready for...

by Dentons on

On 28 April 2017 the Commercial Court of St. Petersburg and Leningrad Region rendered a decision in case No. ?56-87465/2016 (the “Decision”) under the claim of Penobeton-Pikalevo LLC (the “Company”). The case considered the...more

Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings on Certain Spin-Off Debt Exchanges

by Shearman & Sterling LLP on

The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more

Public Mergers and Acquisitions in Canada 2nd Edition - May 2017

by Bennett Jones LLP on

Canadian public merger and acquisition transactions in 2016 (in-bound and out-bound) comprised over C$400 billion in value with at least one-third of the transactions in Canada being fueled by foreign buyers. The second...more

The Evolving Blueprint for Tax Reform: Candidate Trump vs. President Trump

by McNair Law Firm, P.A. on

On April 26, 2017, Treasury Secretary Steven Mnuchin and U.S. National Economic Council Director Gary Cohn, presented the blue print for President Trump’s tax reform proposal (referred to as the “2017 Tax Reform for Economic...more

Emmanuel Macron Elected President: French Taxation to Fall in Line with the European Average?

by Dechert LLP on

Following the election of Emmanuel Macron as President of the French Republic, you will find below a few examples of expected tax changes of potential importance to our clients....more

IRS Issues Guidance on "North-South" Transactions

On May 3, 2017, the IRS released Revenue Ruling 2017-9, which addresses two so-called "north-south" transactions in connection with spin-offs that are intended to be nontaxable under Section 355 of the Internal Revenue Code....more

Taxation of Restructuring Profits in Germany - Tax Administration and Legislator Swiftly React to a Recent Detrimental Decision of...

by Shearman & Sterling LLP on

A recent decision by the German Federal Fiscal Court (BFH) has caused significant concerns in the restructuring community because it will severely complicate future restructurings in Germany or even make them impossible...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

Sweden Rules on Taxation of Carried Interest in Private Equity Structures

by DLA Piper on

Sweden's Administrative Court of Appeal (SACA) has issued a decision on the taxation of carried interest in a number of private equity structures. In most of these structures, carried interest was taxable at least partly as...more

Trump Administration Proposes Tax Reductions

by Jones Day on

On April 26, 2017, the Trump Administration officially announced the President's tax reform plan in a one-page proposal calling for substantial business and individual tax cuts and the elimination of the AMT and many...more

Tackling Tax Reform – Part III: The Timing of Tax Reform

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In this blog post, we focus our attention on the likely timing...more

President Trump’s Tax Proposal

by Fraser Trebilcock on

President Trump recently released his tax reform plan. The proposal aims to drastically cut corporate and individual taxes. The goal is to create economic growth and American jobs, to lower the business tax rate to one of the...more

Have Yourself a Very Trumpy Tax Plan

by Dechert LLP on

Well, we’ve had the big reveal and the administration’s new tax plan is out. This plan, announced with a great deal of fanfare, feels more like a campaign promise than an actual executable plan. At two hundred forty-six...more

Locke Lord Article: Tracking Tax Reform

by Locke Lord LLP on

On April 26, 2017, Treasury Secretary Steven Mnuchin and White House chief economic advisor Gary Cohn announced President Trump’s latest tax reform proposals, titled “2017 Tax Reform for Economic Growth and American Jobs” and...more

S-Corps, Basis & Loss Limitations

by Farrell Fritz, P.C. on

In General- It is a basic principle of federal tax law that a taxpayer cannot, for purposes of determining the taxpayer’s taxable income, claim a loss with respect to an investment in excess of the taxpayer’s unrecovered...more

Fourth Circuit Economic Substance Doctrine

by Alston & Bird on

The Tax Court’s recent opinion in Austin v. Commissioner, TC Memo 2017-69, claims to be following the Fourth Circuit’s view of the economic substance doctrine by calling it the sham transaction doctrine, saying it is an issue...more

Update on US Federal Tax Reform Proposals

by Shearman & Sterling LLP on

On April 26, the Trump Administration made its much-anticipated release of several “core principles” of its tax plan. In doing so, the administration affirmed its desire to enact comprehensive corporate and individual tax...more

Trump releases tax plan: now Congress takes its turn

by DLA Piper on

The release this week of the Trump Administration's tax reform principles, along with the disclosure by Speaker Paul Ryan (R-Wisconsin) of a letter from the Congressional Joint Committee on Taxation relative to the budgetary...more

Business Law Update - May 2017

by Barley Snyder on

Through June 19, the Pennsylvania Tax Amnesty Program will waive all penalties and slash the interest rate on outstanding tax delinquencies that existed as of the end of 2015. Both the state and the Pennsylvania Department of...more

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