Corporate Taxes

News & Analysis as of

California Enacts Federal Conformity Bill

The governor of California has signed AB 154, which selectively conforms the California Revenue and Taxation Code to specified provisions of the Internal Revenue Code enacted as of January 1, 2015. This is a significant...more

Economic Presence Standard for Income Tax Nexus

In a question of first impression for Illinois, on May 12, 2015, Judge Schmidt of the Circuit Court of Sangamon County granted a summary judgment for the Illinois Department of Revenue, holding that the proper test for...more

Breaking News: California Supreme Court Hears Long-Awaited Gillette Oral Argument

On October 6, 2015, counsel for the taxpayer and the Franchise Tax Board (“FTB”) argued before the California Supreme Court in The Gillette Company & Subs. v. California Franchise Tax Board. This case has been watched closely...more

[Webinar] Tax Planning for Investments Into Brazil - Oct. 14th, 12:00pm ET

Please join us on Wednesday, October 14th at 12:00pm EST for an in-depth joint presentation by tax attorneys, Jeffrey Rubinger of Bilzin Sumberg and Fernando Martins of WFaria Advogados on the cross-border tax considerations...more

Tax Policy Update

The number of “Action Items” detailed in the OECD’s report released yesterday to combat base erosion and profit shifting strategies among multinational corporations. The recommendations have drawn criticism from some GOP...more

Entering the U.S. Without Entering Its Tax System: Holding Company Structures for U.S. Operations

Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Basic Tax Issues in Mergers and Acquisitions

Mergers and acquisitions ("M&A") are complex, multilayered transactions with multiple moving parts and a healthy dose of negotiation. There are, however, common tax implications at play in most transactions of which...more

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Business Incentive Changes in Recent North Carolina Legislation

The North Carolina General Assembly passed two significant pieces of legislation affecting corporate activity, expansion and new investment in North Carolina. First, the General Assembly passed the state budget...more

Global Tax News: US Congress: tax reform emerging as major 2016 campaign issue – financial industry a prime target

Tax reform is emerging as a major issue in the 2016 US presidential campaign, and in the growing wave of populist anger at the establishment elite in Washington and Wall Street, the financial industry has become a prime...more

Global Tax News: Belgium Adopts New Fiscal Measures

The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to...more

Tax Policy Update

NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

Inside the IRS Plan to Erase Goodwill Tax Exception

On Sept. 14, 2015, the IRS released proposed regulations that would significantly alter the treatment of outbound transfers of foreign goodwill and going concern value by a U.S. person to a foreign corporation. Under the...more

Australian Tax Alert: Double Taxation Agreement with Israel

Whilst Australia and Israel already share a close relationship, a DTA will serve to strengthen the economic ties between the countries. A DTA will provide greater tax certainty for business, enhance both countries' tax...more

Non-Securities Dealer Corporations Have Until September 30, 2015 to Comply with Investment Capital Identification Procedures for...

This is an important reminder that non-securities dealer corporations subject to New York State and City corporate tax have until September 30, 2015 to identify stock as investment capital in order for the stock to qualify as...more

Tax Review - September 2015

We are proud to present the next edition of our “Tax Review” which contains a selection of rulings and interpretations that had been issued or published in August 2015. We hope you will find the information provided here...more

Six Recommendations For Clients With Connections to France

There have been a number of changes to EU laws recently that have had, or will have, a direct impact on your clients who have connections with France. There are six stand-out issues that are worth careful and immediate...more

Tax Court Holds that Residual Value Insurance Qualifies as Insurance for Tax Purposes

On September 21, the United States Tax Court held in favor of the taxpayer in R.V.I. Guaranty Co., Ltd. and Subsidiaries v. Commissioner, 145 T.C. No. 9 (2015). The court concluded that the residual value insurance policies...more

North Carolina Tax Reform (2015 Edition)

North Carolina’s General Assembly is continuing the overhaul of the State’s tax system that it began in 2013. That year, the General Assembly slashed corporate and individual tax rates, eliminated many income tax deductions...more

Australian Tax Alert: Australia Pursues Multinational Tax Avoidance

In the context of the imminent release of the OECD report to G20 finance ministers (in October 2015) dealing with its final recommendations on the Base Erosion Profit Shifting (BEPS) Action Plan, Australia has introduced...more

Tax Policy Update

The number of working days (in theory) that Congress has left to negotiate and pass a continuing resolution (CR) that would keep the government from shutting down on Oct. 1. Here’s hoping that the Pope’s visit to the Capitol...more

Corporate Alert: The Luxembourg Special Limited Partnership

Largely inspired by the Anglo-Saxon limited partnership regimes, the special limited partnership (SLP) has been designed to bolster Luxembourg’s position as the main alternative investment fund structuring hub in the EU at a...more

Doing Business in Canada

This Guide provides non-Canadians with an introduction to the laws and regulations that affect the conduct of business in Canada and, in particular, in the province of Ontario. In some cases, this Guide also identifies issues...more

Recently Signed North Carolina Budget Includes Important Tax Changes

Nearly three months after the beginning of North Carolina’s fiscal year, on September 18 the state General Assembly finally adopted a budget for the next two years which was signed by Governor Pat McCrory on the same...more

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