News & Analysis as of

Cross-Border Transactions Internal Revenue Service

Cadwalader, Wickersham & Taft LLP

Treasury Finalizes “Killer B” Regulations with Few Adjustments

On July 17, the U.S. Treasury and IRS released final regulations targeting various inbound cross-border transactions broadly referred to as “Killer B” transactions, marking the end (for now) of a long-running regulatory fight...more

McDermott Will & Emery

United States v. Eaton: IRS Summons Power Overrides EU Privacy Laws

A US federal district court judge recently endorsed the broad investigative powers of the Internal Revenue Service (IRS) in United States v. Eaton Corp., No. 1:23-mc-00037, May 16, 2024 (N.D. Ohio). During its audit of...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Proskauer - Employee Benefits & Executive...

Stranger in a Strange Land: Surprising Applications of U.S. Golden Parachute Rules in Cross-Border Transactions

Background - The “golden parachute” excise tax regime under Internal Revenue Code Sections 280G and 4999 (“Section 280G” and “Section 4999”, respectively) is at the core of both public and private U.S.-based transactions....more

Dorsey & Whitney LLP

Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property

Dorsey & Whitney LLP on

Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as...more

Freeman Law

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

Freeman Law on

Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Cadwalader, Wickersham & Taft LLP

A Peek Behind the Curtain: IRS Musings on Spinoff Ruling Procedures

Speaking at several tax conferences this month, several senior IRS officials, including the Associate Chief Counsel, Corporate, discussed the nuances of the device requirement for spinoffs and signaled a willingness to relax...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 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 December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Alston & Bird

Proposed Regulations Classifying Cloud Transactions and Digital Content Released

Alston & Bird on

Our International Tax Group downloads Treasury and the IRS’s attempt at updating the tax implications of computer transactions for the 21st century....more

Sheppard Mullin Richter & Hampton LLP

IRS Change in Application Requirements for Obtaining Employer Identification Number Could Affect Many International Investors in...

Effective May 13, 2019, the Internal Revenue Service (IRS) changed the requirements for obtaining an employer identification number (EIN}. The IRS no longer permits an entity to be named as the “responsible party” on IRS Form...more

Sheppard Mullin Richter & Hampton LLP

Revised EIN Application Process Permits only Individuals to Serve as the “Responsible Party”

An entity operating in the U.S. needs a U.S. Federal employer identification numbers (“EIN”) in order to open a bank account in the United States, act as an employer, file a tax return and complete certain other corporate...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

More on the rather shocking departure of John Flannery from GE, the Board that didn’t want to give him any more leash for his turnaround plans, and the future of the embattled corporate giant under Larry Culp....more

Latham & Watkins LLP

Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform

Latham & Watkins LLP on

New regulations more notable for what they retain than what they change. Key Points: ..The US anti-inversion rules have more than a 15-year history of impacting the structure and practicality of certain cross-border...more

Sheppard Mullin Richter & Hampton LLP

Opening a U.S. Bank Account Can be Much More Onerous than you Think and Can Delay Your Cross-Border Transaction or Growth Plans in...

French investments in the U.S. vary largely in terms of scale and nature, but whatever it is a small French startup only creating an even smaller U.S. subsidiary or a large French corporation acquiring and restructuring an...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Enacts the Most Comprehensive Changes in Three Decades

The sweeping tax bill that President Donald Trump signed into law on December 22, 2017, represents the most comprehensive reform of U.S. tax law since 1986. The law makes substantial changes to the taxation of individuals and...more

Eversheds Sutherland (US) LLP

No Comment: Temporary Anti-Inversion Regulation Rejected Under Administrative Procedure Act

On Friday, September 29, 2017, the Federal court for the Western District of Texas struck down the temporary anti-inversion regulation issued under Sec. 7874, which has been charged with preventing the planned $160 billion...more

Seyfarth Shaw LLP

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Foodman CPAs & Advisors

First FATCA Conviction!

On May 9, 2016, the Department of Justice (DOJ) announced its first FATCA conviction. It appears to be the beginning of criminal prosecutions by the DOJ against apparent or alleged violations of FATCA reporting requirements....more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Alston & Bird

Proposed Regulations Nix Foreign Goodwill Exception to Tax on Outbound Transfers

Alston & Bird on

The IRS and Treasury recently issued proposed regulations under Section 367 with bad news for taxpayers. Citing aggressive taxpayer positions, the proposed rules do away with the foreign goodwill exception and restrict the...more

McGuireWoods LLP

Tax Policy Update

McGuireWoods LLP on

After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

Farella Braun + Martel LLP

Final Regulations Provide Guidance for Private Foundations Making Foreign Grants

When making grants to foreign organizations, private foundations must conduct costly and time-consuming expenditure responsibility, unless the foundation makes a good faith determination that the foreign organization is...more

27 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide