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Cross-Border Controlled Foreign Corporations

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Bracewell LLP

Focus on Finance: Tax Reform and the Banking Industry Revisited

Bracewell LLP on

The Tax Cuts and Jobs Act (TCJA) has far-reaching implications for the banking and finance industry. In our very first Bracewell Tax Report, we noted certain issues that companies might consider when evaluating their...more

Jones Day

UK Cites Security Reasons for Proposed Deal Notification Regime

Jones Day on

A consultation paper on national security and investment published by the UK government advocates extensive changes to current provisions regarding foreign investment in UK businesses. In essence, the proposed changes would...more

Carlton Fields

Tightening the Tax Screws on International IP Structures

Carlton Fields on

For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more

Dechert LLP

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

Dechert LLP on

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

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