News & Analysis as of

Corporate Taxes Offshore Funds

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

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Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Proskauer Rose LLP

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

Holland & Knight LLP

Large Corporations and Wealthy Taxpayers Beware: The Taxman is Coming

Holland & Knight LLP on

Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more

Conyers

Hard Deadline for Filing 2019 Economic Substance Return Upcoming on 30 April 2021

Conyers on

Relevant entities carrying on all types of relevant activity (except for those carrying on intellectual property business) under the International Tax Co-operation (Economic Substance) Act (2021 Revision) (“ES Act”) with a...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Closer Look at Biden’s Tax Proposals

Former Vice President Joseph Biden has proposed a number of fundamental changes to the tax code over the course of his campaign. If he is elected president and if the Democrats keep control of the House of Representatives and...more

Dechert LLP

COVID-19: UK Tax Residence Risks for Offshore Funds and Related Entities

Dechert LLP on

Non-UK resident companies play a variety of roles in fund structures managed by UK based asset managers. They are commonly used as the fund vehicle itself, as the general partner of a limited partnership fund vehicle, and/or...more

McDermott Will & Emery

Weekly IRS Roundup July 15 – 19, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15 – 19, 2019. July 16, 2019: The IRS issued a news release concerning its provision of...more

McDermott Will & Emery

IRS Announces More LB&I Campaigns!

McDermott Will & Emery on

The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more

Foodman CPAs & Advisors

IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready!

Foodman CPAs & Advisors on

On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more

Orrick, Herrington & Sutcliffe LLP

IRS Extends Date for Section 965 Liability Transfer Agreement

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

Butler Snow LLP

Section 965 Proposed Regulations Issued

Butler Snow LLP on

On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Proskauer Rose LLP

Tax Round Up - April 2017

Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

Dechert LLP on

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

The Volkov Law Group

The Legacy of Michigan Senator Levin and Offshore Taxation Issues

The Volkov Law Group on

When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to...more

BakerHostetler

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

BakerHostetler on

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

Williams Mullen

Chairman Baucus Issues a Discussion Draft on Tax Reform

Williams Mullen on

Chairman Max Baucus has issued a discussion draft that offers some interesting and provocative proposals on corporate international tax reform. Designed to “reform international tax rules to spark economic growth, create...more

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