News & Analysis as of

Corporate Taxes Multinationals

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

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

The proposed US tax reform: repatriation alternatives for multinationals operating in Latin America

by DLA Piper on

The proposed US tax reform may incentivize multinational companies that have made investments in Latin America to pursue repatriation alternatives such as dividend distributions and capital reduction. However, the...more

Trump Administration and Congressional Leaders Release Tax Reform Framework

by Shearman & Sterling LLP on

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

Republicans release new tax reform framework

by Dentons on

On September 27, 2017, the Trump administration and Republican leaders in Congress released their "Unified Framework for Fixing our Broken Tax Code." This nine-page document is the result of months of meetings on tax reform...more

2018 Dutch Tax Plan - changes to Dutch dividend withholding tax

by DLA Piper on

The Dutch Ministry of Finance has published the 2018 Budget and, in connection with it, the 2018 Tax Plan. The 2018 Tax Plan contains a number of already anticipated changes to Dutch tax legislation effective as of January 1,...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

by Dorsey & Whitney LLP on

Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

by Bilzin Sumberg on

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

The Impact of Tax Reform on Private Equity

If the past 12 months have taught us anything, it’s that the future is hard to predict. One need only look at the ascendancy of Brexit, President Donald Trump, or even the New England Patriots in the second half of the Super...more

China Tax Newsletter - January / February 2017

by DLA Piper on

Welcome to the latest issue of our Tax Newsletter. In the past two months, there are a number of developments in the tax world in the PRC and Hong Kong. In the PRC, the State Administration for Industry and Commerce...more

The U.S. Tax Reform and the Energy Sector

by Hogan Lovells on

President Donald Trump and Republican Congressional leaders have promised a major reform to the U.S. tax code in 2017. This reform, if anything close to these promises, will have significant implications for the energy...more

US Tax Reform: Strategies for Executing Transactions in the Face of Uncertainty

by Latham & Watkins LLP on

Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups. Key Points: ..Tax reform...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

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

Budget 2017

by Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

by Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Base erosion and profit shifting - new regulations

by Hogan Lovells on

International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more

Tax reform: Are you ready for the storm?

by Dentons on

You may want to think of tax reform as a pending storm. First, it is sorely needed; it has been a long time since we had the last real one. Second, even though we see storm clouds gathering, we are not exactly sure when it...more

German tax law changes and their impact on multinationals

by DLA Piper on

On 2 December 2016, the Act for the implementation of the amendments of the EU Administrative Cooperation Directive and of further measures to counter base erosion and profit shifting - having been approved by the Lower House...more

Country by Country: Luxembourg introduces law on country-by-country reporting

by DLA Piper on

On the 13th of December, the Luxembourg parliament voted in favour of a law on country-by-country reporting (CbCR). The conditions for a Luxembourg tax resident company to be subject to CbCR are the following...more

Country by Country: Spain

by DLA Piper on

The new Spanish Corporate Income tax Regulations were approved on 11 July 2015 through the Royal Decree 634/2015, which complement the provisions included in the Spanish Corporate Income Tax Law (Law 27/2014) that entered in...more

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