News & Analysis as of

Corporate Taxes Capital Gains

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

Auf Wiedersehen to the tax privilege on restructuring gains – a blow to the German restructuring tool kit

by White & Case LLP on

A recent judgment of the German Federal Fiscal Court (FFC) will have significant impact on the restructuring tool kit afforded under German law. The FFC has found that the existing practice of permitting a tax liability...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

When A “Tax Free” Exchange May Not Be Free of Tax

by Farrell Fritz, P.C. on

“Tax free” – two words that often bring great delight when they are spoken by a tax adviser to the owner of a business, whether he is considering the disposition of a single asset, or of substantially all of the assets, of...more

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

by Snell & Wilmer on

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

French Finance Act for 2017 and Amending Finance Act for 2016: the Most Important Changes Affecting Businesses

by K&L Gates LLP on

The French Finance Act for 2017 and Amending Finance Act for 2016 were enacted on December 30, 2016 (the “Acts”). The Acts introduce a progressive reduction of the corporate income tax rate (28% instead of 33.1/3%). The Acts...more

Change is Coming: A Look at Trump and Republican Tax Proposals

by Barley Snyder on

Tax reform is coming, and you better be ready. Regardless of how you voted in November, the United States will have a new president Friday and the Republican Party will be in control of both houses of Congress....more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Global Private Equity Newsletter - Winter 2017 Edition: President Trump: The Outlook for Private Equity

by Dechert LLP on

All eyes are on Washington—or should we say Manhattan—these days, searching for clues about where our ship is heading with U.S. President-elect Donald Trump at the helm. Recently, there have been cabinet appointments to...more

Trump Administration's Tax Reform Likely

by Hodgson Russ LLP on

Donald J. Trump defied the polls and much of the national media to win the US presidential election on November 8, 2016. President-elect Trump will be sworn in and will take office as the 45th president of the United States...more

A Comparison of Trump and House GOP Tax Reform Proposals

by Holland & Knight LLP on

With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform, with...more

What Kind of Tax Changes Can We Expect From Trump's Presidency?

by Charles (Chuck) Rubin on

The tears have not yet dried for some, and the celebrating is not yet over for others, but let's turn our attention to taxes. With a Republican Congress and a Republican president, some measure of tax relief is a given. What...more

Luxembourg Real Estate - Tax and Legal Developments

by Dentons on

This brief report provides a summary of the most recent Luxembourg tax developments that currently affect and will be affecting real estate practitioners throughout 2017....more

Using corporate structures to own UK residential property – a dead end?

by Dechert LLP on

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

MoFo Tax Talk - Volume 9, No. 3

by Morrison & Foerster LLP on

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

U.S. Tax Competitiveness is Abysmal (and Economic Freedom is Trending Downward)

by Charles (Chuck) Rubin on

Capital, and all the benefits it provides (investment, innovation, jobs, creation of wealth), flows to where it is treated best. An important element of treatment is how it is taxed. So how does U.S. tax competitiveness...more

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Exclusion for Qualified Small Business Stock

by Foley & Lardner LLP on

The Protecting Americans from Tax Hikes Act, passed in December 2015, extended an often overlooked provision of the tax code with the potential to provide significant savings to small business owners and non-corporate...more

Safe Harbor Acquisition of Control for Spin-Offs

by Charles (Chuck) Rubin on

Code Section 355, and related Code provisions, when applicable, will allow a corporation to spin-off or split-off a subsidiary corporation to its shareholders without triggering gain to the corporation or its stockholders....more

"IRS Expands REIT Spin-Off Restrictions, Extends REIT Built-in Gains Period to 10 Years"

On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all merger-and-acquisition activity by C corporations and real estate investment...more

Private equity in Italy: market and regulatory overview

by Latham & Watkins LLP on

How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more

UK Budget Residential Property Alert - March 2016

by McGuireWoods LLP on

The Chancellor’s budget last week has been largely viewed as a business-friendly budget but it also contained some surprise announcements particularly for those who invest in, acquire and develop both residential and...more

UK Budget 2016: Tax implications for the private equity sector

by Reed Smith on

The private equity sector was a net loser from last week’s Budget, with the proposed restrictions on interest deductibility and a lifetime limit on employee shareholder schemes. The extension of entrepreneurs’ relief is...more

Tax Announcements in the UK’s Budget 2016

by Proskauer - Tax Talks on

The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our...more

UK Tax Measures—Spring 2016 Budget

by Morgan Lewis on

The spring budget includes a number of announcements that relate to taxation, the most significant of which is a “roadmap” for UK corporate taxation through 2020....more

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