Corporate Taxes

News & Analysis as of

What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions [Video]

Partner and Chair of BakerHostetler's Tax Group, Paul Schmidt, discusses tax inversions. What CEOs and Board of Directors should be asking themselves?...more

U.S. Treasury Department Takes Action to Slow (But Not Stop) Corporate Inversions: A Summary for Executives

What is an inversion? An inversion is a transaction that results in an existing U.S. company becoming a foreign company or becoming a subsidiary of a foreign parent. Historically, inversions involved U.S. companies...more

Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?

It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more

Legal Alert: New York Tax Appeals Tribunal Reverses “Distorted” Knowledge Learning Decision and Provides Guidance for Proving...

On September 18, 2014, the New York State Tax Appeals Tribunal (Tribunal) decided its first combination case addressing the 2007 changes to New York’s combined reporting regime: Matter of Knowledge Learning Corporation and...more

Department of the Treasury and the Internal Revenue Service to Issue Regulations Limiting Taxpayers’ Ability to Benefit from...

On September 22, 2014 the Department of the Treasury and the Internal Revenue Service provided official notice to taxpayers of their intention to issue regulations limiting taxpayers’ ability to benefit from undertaking...more

Alert: IRS and Department of the Treasury Notice Limits Inversion Transactions

On September 22, 2014, the United States Department of the Treasury and the Internal Revenue Service issued a Notice (Notice 2014-52) that limit "inversion" transactions and their potential tax benefits. In general, an...more

Guide To Doing Business in Australia: Competition and Consumer Protection

COMPETITION AND CONSUMER PROTECTION - Australia has extensive competition and consumer laws dealing with, among other things, the promotion of competition and consumer protection. This section provides an introduction...more

VAT Alert: Cross-Border Supplies Of Services Made To VAT Grouped Branches: Skandia America Corp. (USA), filial Sverige (C-7/13)

For VAT purposes, a supply of services from the headquarters of a company to its branch is generally not subject to VAT. This is well-established, and was confirmed in the Court of Justice of the European Union (the "Court of...more

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

Philadelphia School Income Tax Imposed on Undistributed S Corporation Income

The City of Philadelphia Revenue Department (“City”) is assessing the School Income Tax (“SIT”) on the entire share of a resident S Corporation shareholder’s income, whether or not distributed. The assessments reach back to...more

Treasury Takes Action Against Corporate Inversions

Earlier this week, the Treasury Department and the IRS announced that they would issue regulations that substantially limit the U.S. tax benefits of corporate inversions (and certain post-inversion transactions)....more

Skandia: Intra-Company Supplies Treated as Taxable Transactions for VAT Purposes by the Court of Justice of the European Union

On 17 September 2104, the Court of Justice of the European Union (the “CJEU”) gave its preliminary ruling in the case of Skandia America Corporation USA, Sweden Branch v Skatterverket (C-7/13) (“Skandia”). The decision of...more

International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

New Treasury rulemaking aims to curb advantages of inversion - will this affect your deal?

Yesterday, following a summer during which a number of major American companies announced plans to invert (i.e., shift their tax domiciles overseas following cross-border mergers), the US Treasury Department issued a notice...more

Monitoring recent Swiss tax developments: key takeaways

In the realm of multinational corporate tax planning, Switzerland has long been a key jurisdiction due to its generally attractive business attributes (solid infrastructure and multilingual, skilled workforce) and competitive...more

Tax Newsletter - July/August 2014 (China & Hong Kong)

Welcome to the latest July/August 2014 issue of our Tax Newsletter. We saw a number of legislative developments taken place in the PRC and Hong Kong in the past two months that might bring about legal and tax...more

Base erosion profit shifting project recommendations to combat tax avoidance by multinationals

At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering 15 key elements to be addressed by 2015 for a co-ordinated international approach to combat tax...more

Devon: TCC considers large corporation rules

In Devon Canada Corporation v. The Queen the issue is whether the taxpayer (“Devon”) may deduct $20,884,041 paid to cancel issued stock options. After the close of pleadings, the Crown brought a procedural motion relating to...more

Guide To Doing Business in Australia: Taxation

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Why Does My Joint Venture Pay Corporate Taxes? When Tax Status Doesn’t Match State Form

Most of the time the state-law classification of an entity and its federal income tax classification match. A corporation will be taxed as a corporation and a partnership will not be taxed, instead merely filing an...more

RRSP Eligibility for Renewable Energy Co-Operatives: Could there be a solution at last?

One of the major obstacles facing renewable energy co-operatives is the concern that, although they are a co-operative for the purposes of the Cooperative Corporations Act (Ontario) (the “CCA”), they may not be co-operatives...more

Illinois Enacts Legislation Imposing a Self-Procurement Tax While Also Narrowing the Industrial Insured Exception for Transacting...

Illinois will soon begin taxing self-procured insurance premiums for the first time, as required by Senate Bill 3324, now Public Act 98-0978 (the Act). The Act, which was signed into law by Governor Quinn on August 15, was...more

Increase of ratio of film support

On 24 June 2014 the European Commission resolved that it does not object to an increase in indirect state support (in the form of a tax rebate), from 20% to 25%, for the production costs of films produced in Hungary. It is...more

Gariepy: When is a director’s resignation effective?

In Gariepy v. the Queen (2014 TCC 254), the Tax Court considered (i) whether two directors had effectively resigned from their positions, and (ii) if not, whether the directors were duly diligent in seeking to prevent the...more

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