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Corporate Taxes U.S. Treasury Multinationals

Holland & Knight LLP

Biden Administration's FY 2022 Budget and International Tax Changes

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A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

Jones Day

Warning: U.S. Tax Regulations Impact Completed Foreign Sales Retroactively and Domestic Partnerships

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The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more

A&O Shearman

Final GILTI Regulations and Proposed Regulations on Subpart F Income and GILTI Bring Relief to Private Equity and Other...

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On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - June 2019

In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

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Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

BCLP

Proposed Regulations Impact Treatment of CFC Pledges and Guarantees

BCLP on

On October 31, 2018, the Treasury Department released proposed regulations (the “Proposed Regulations”) that reduce certain amounts otherwise includible in the taxable income of a corporate U.S. shareholder of a controlled...more

Burns & Levinson LLP

The Death of the Deemed Dividend

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The “deemed dividend” rule, the source of much wrangling between multi-national borrowers and lenders over the years, may be on its way out....more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

A&O Shearman

Brexit and Other Key Issues for CFOs and Corporate Treasurers

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On June 23, 2016, the UK electorate voted to leave the European Union in an advisory Referendum. We expect the UK Government to commence negotiations to withdraw and to establish a framework for the UK’s new relationship with...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

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Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

Latham & Watkins LLP

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

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New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

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For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

European Commission Unveils Tax Transparency Package - The European Commission has laid out its plans in a new Tax Transparency Package to clamp down on tax deals made between EU governments and multi-national...more

Dechert LLP

The New Landscape for Inversions: IRS and Treasury Change the Rules

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The Internal Revenue Service (“IRS”) and Treasury Department issued Notice 2014-52 (the “Notice”) targeting corporate inversions on September 22, 2014 (the “Notice Date”) in the U.S. Tax considerations are important for...more

Bilzin Sumberg

“Return of Basis” Repatriation Strategy Tested in Tax Court

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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

BakerHostetler

Legislative Update Tax Reform—A Work in Progress

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With high tax rates and a worldwide (as opposed to territorial) system of taxation, U.S. corporate tax laws encourage new multinational corporations to organize outside the U.S. and encourage existing U.S. corporations to...more

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