News & Analysis as of

Corporate Taxes

Tax planning for private corporations and their shareholders - converting income into capital gains

by Dentons on

On October 19, 2017, the Department of Finance Canada issued a news release advising that it will not move ahead with proposed measures intended to target the conversion of income into capital gains. The announcement is the...more

Pennsylvania Supreme Court Finds Flat-Dollar NOL Cap Unconstitutional, But Upholds Percentage Cap

The Pennsylvania Supreme Court held that the state’s flat $3 million cap on net operating loss (NOL) carryforwards violates the state constitution’s Uniformity Clause. Unlike the lower court, however, the Supreme Court left...more

Taxation of private corporations and their shareholders

by Dentons on

On July 18, 2017, the Department of Finance Canada introduced draft legislative proposals impacting private corporations and their shareholders. A 75-day consultation period was provided with a deadline for taxpayer...more

Ambitious Tax Reform Takes Center Stage

by Akerman LLP on

The Trump Administration and certain members of Congress recently released an ambitious, conceptual plan for tax reform that would drastically alter current U.S. tax law, affecting a wide array of taxpayers. The plan (called...more

Branching Out: Nonfunctional Currency Branch Regulations Targeted for Burden Reduction

On October 2, 2017, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2017-57 (the Notice) announcing that Treasury and the IRS: - Are considering changes to the final...more

Tax Planning is Crucial to Achieve Potential Spin-Off Benefits

by Proskauer - Tax Talks on

Today, the Wall Street Journal considers again, on its front page above the fold, the potential benefits of corporate spin-off transactions. The Journal article notes that the S&P Spin-Off Index has outperformed the S&P 500...more

Congressional Republicans and White House Release Outline of Tax Reform Proposal

by Baker Donelson on

On September 27, the White House and its allies on Capitol Hill released the outline of their long-promised tax reform proposal. Generally, the outline seeks to create three individual income tax rates (12, 25, and 35...more

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

by Jones Day on

The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

Framework for Tax Reform Released

by Williams Mullen on

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released a unified framework (the Framework) with the stated goal of achieving pro-American,...more

M&A Tax Aspects of Republican Tax Reform Framework

by McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

September 2017: An Update on UK Tax Disputes Including the New UK Corporate Criminal Offense: What Is It and What Should You Do...

Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more

Anti-Inversion Regulations Held to Violate Administrative Procedure Act

by King & Spalding on

On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more

France Welcomes Foreign and Alternative Capital Providers with Latest Reform of Finance Sector

Long a cornerstone of the French banking system, the "French banking monopoly" largely prevents non-bank entities from lending money to French borrowers. Although French funds have been used as vehicles by alternative capital...more

IRS Opens Pilot Program on Tax-free Spin-offs

by Jones Day on

The Situation: In 2013, the IRS ceased issuing private letter rulings confirming the general tax consequences of tax-free spin-offs....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 which reflects President Trump’s new tax plan. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax...more

Tax Reform Update: A Call for Committee Action

by McNair Law Firm, P.A. on

On September 27, 2017, the Secretary of the Treasury, the Director of the National Economic Council, the Chair of the U.S. House Ways and Means Committee, the Chair of the U.S. Senate Finance Committee, the Speaker of the...more

Republicans Announce Tax Reform Framework, Which Includes Repealing Estate Tax

After months of speculation, President Trump and the Republicans have announced their framework for tax reform. While specific details are not known, the key elements of the framework include...more

The Republican Tax Reform Framework: What It Says and What It Doesn’t

by Alston & Bird on

Tax reform is coming, and Republican leaders have published a framework that raises as many questions as it answers. Our Tax Policy & Regulation Team investigates what the Big Six reveal and—just as important—what they don’t....more

Tax Change Planning

by Alston & Bird on

With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking....more

The White House Framework for Tax Legislation

On September 27, the White House released a document called the “Unified Framework for Fixing Our Broken Tax Code,” containing an outline prepared by the administration plus the senior Republican members of the tax-writing...more

Unified Framework for Tax Reform

by Ballard Spahr LLP on

President Donald J. Trump and the "Big Six"—House Speaker Paul Ryan (R-WI), Senate Majority Leader Mitch McConnell (R-KY), Treasury Secretary Steven Mnuchin, White House adviser Gary Cohn, House Ways & Means Committee...more

More Specifics Come Out in New Trump Tax Plan

by Barley Snyder on

The Trump administration on Wednesday released its “Unified Framework for Fixing Our Broken Tax Code.” The reforms outlined in the documents provide more specificity than prior White House plans, but a number of specifics...more

Tax Law Alert: “Big Six” Release Tax Reform Framework Supported by President Trump

by Stoel Rives LLP on

After months of speculation a group of Republican leaders referred to as the “Big Six” (House Speaker Paul Ryan, Senate Majority Leader Mitch McConnell, House Ways and Means Committee Chairman Kevin Brady, Senate Finance...more

U.S. Tax Reform Effort Moves Forward

by Hogan Lovells on

On September 27, 2017, Republican leaders of the tax reform effort in the U.S. House of Representatives, the U.S. Senate, and the Trump Administration released a "Unified Framework for Fixing Our Broken Tax Code," providing...more

Thou Shalt Not Hold Real Property In A Corporation

by Farrell Fritz, P.C. on

“When will they ever learn?”- No, I am not channeling Seeger. I am referring to those individuals[i] who continue to acquire real property (“RP”) in, or who contribute RP to, corporations. In just the last couple of...more

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