News & Analysis as of

Cross-Border Transactions Tax Reform

Walkers

The British Virgin Islands and the EU List of Non-Cooperative Tax Jurisdictions

Walkers on

The EU has announced it is has added the British Virgin Islands (BVI) to its list of non-cooperative jurisdictions for tax purposes. The BVI Government has since issued a statement highlighting that it has already introduced...more

Bennett Jones LLP

Canada Introduces "Excessive Interest and Financing Expenses Limitation"

Bennett Jones LLP on

Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: US Tax Reform and Cross-Border M&A: Considering the Impact, One Year In

Many of the core provisions in the Tax Cuts and Jobs Act (TCJA) — including the corporate tax rate reduction and the fundamental reworking of the U.S. international tax regime — were geared toward addressing the uncompetitive...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

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Cross-Border Estate Planning

The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more

Skadden, Arps, Slate, Meagher & Flom LLP

Strategic Imperatives, Market Confidence Drive US M&A

2017 was another active year for mergers and acquisitions, both in the United States and globally, though the overall dollar volume of deals continued to lag behind 2015’s record levels. Global M&A activity was relatively...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

McDermott Will & Emery

The Senate’s New Base Erosion Tax: Highlights for Renewable Energy

McDermott Will & Emery on

On December 2, 2017, the Senate approved its version of the Tax Cuts and Jobs Act. The Senate Bill includes the base erosion and anti-abuse tax, a new tax intended to apply to companies that significantly reduce their US tax...more

Orrick, Herrington & Sutcliffe LLP

The Impact on Financing Transactions if the House’s “Tax Cuts and Jobs Act” Passes

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act (“H.R. 1”), and later proposed amendments to the bill on November 3, November 6, and...more

Seyfarth Shaw LLP

Strategic Planning in Uncertain Times: A “How To” for Businesses

Seyfarth Shaw LLP on

If you are a company whose growth, profitability, operating costs or business model is directly or indirectly affected by what happens in national politics, how are you prepared to engage in effective business and strategic...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Disclosure Trends Related to Brexit and the Trump Administration

The Brexit vote and President Donald Trump’s election and proposed regulatory and other reforms have led to worldwide geopolitical uncertainty. We expect reporting companies will continue to disclose risk factors relating to...more

Jones Day

French Tax Update - Prior Approval of Cross-Border Reorgs, Abusive Sale and Lease-Back Transaction, Official Guidelines on Foreign...

Jones Day on

The present French Tax Update provides an overview of several significant publications issued between the end of 2016 and the first months of 2017...more

Skadden, Arps, Slate, Meagher & Flom LLP

"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

Seyfarth Shaw LLP

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

Seyfarth Shaw LLP on

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Looking Ahead: The U.S. Legal and Regulatory Environment Under a Trump Administration"

Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more

McGuireWoods LLP

OECD Releases Final BEPS Recommendations – Now What?

McGuireWoods LLP on

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

Troutman Pepper

International Tax Grows Up: The Tax Section at 75, Subpart F at 53, and the Foreign Tax Credit at 97

Troutman Pepper on

As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more

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