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Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint

Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more

Foodman CPAs & Advisors

Alivio Del IRS Para Ciertos Documentos Internacionales Presentados Tarde

Foodman CPAs & Advisors on

El 11/08/23, el IRS anunció que, en las circunstancias adecuadas, los contribuyentes internacionales podrán utilizar una nueva herramienta totalmente electrónica para presentar solicitudes de alivio de multas del IRS para...more

Foodman CPAs & Advisors

IRS Relief For Certain Late-Filed International Documents

Foodman CPAs & Advisors on

On 8/11/23, the IRS announced that under the right circumstances, international taxpayers will be able to use a new, fully electronic tool to submit penalty IRS relief requests for a few late-filed forms: a fax...more

Arnall Golden Gregory LLP

AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders

In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Hogan Lovells

Dividend income is excluded from the EBITDA for the purpose of the Spanish interest limitation rule

Hogan Lovells on

The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more

Brownstein Hyatt Farber Schreck

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Freeman Law

Reviewing a Foreign Legal Structure

Freeman Law on

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

Miller Nash LLP on

The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

Freeman Law

Navigating the Branch Profits Tax

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The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Freeman Law

The Tax Court in Brief - January 2021

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

McDermott Will & Emery

[Webinar] Novità Fiscali Fine 2020 - January 21st, 3:00 pm - 5:00 pm CET

McDermott Will & Emery on

Proseguendo una consuetudine dello Studio, che ha sempre raccolto l’interesse e l’approvazione da parte Vostra, abbiamo organizzato, quest’anno in formato webinar, un incontro sulle principali novità fiscali recentemente...more

McDermott Will & Emery

[Webinar] Tax News At The End Of 2020 - January 21st, 3:00 pm - 5:00 pm CET

McDermott Will & Emery on

Continuing a practice of the Firm, which has always garnered your interest and approval, we have organized, this year in webinar format, a meeting on the main tax innovations recently introduced and of interest to businesses....more

Freeman Law

Everything That You Need To Know About International Tax Penalties

Freeman Law on

International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

McDermott Will & Emery

[Event] Tax in the City® - June 3rd, Seattle, WA

We invite you to join us for our Tax in the City®: A Women’s Tax Roundtable in Seattle. We plan to discuss, among other topics, post-TCJA tax treatment of foreign branches (and disregarded entities), new BEAT guidance, an...more

McDermott Will & Emery

[Event] Tax in the City®: A Women's Tax Roundtable - March 12th, Seattle, WA

McDermott Will & Emery on

Mark your calendars for our spring 2020 Tax in the City®: A Women’s Tax Roundtable in Seattle—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and...more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Jones Day

U.S. Treasury Releases Proposed FIRPTA Regulations

Jones Day on

New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...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

Foodman CPAs & Advisors

Understanding How to Compute a U.S. shareholder’s GILTI inclusion

The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more

Proskauer Rose LLP

UK Tax Round Up - December 2018

Proskauer Rose LLP on

UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more

Proskauer Rose LLP

UK Tax Round Up - April 2018

Proskauer Rose LLP on

General UK tax developments - Changes to taxation of termination payments - HMRC has updated its Employment Income Manual to reflect the changes to the taxation of termination payments (including payments in lieu of...more

Proskauer Rose LLP

UK Tax Round Up - February 2018

Proskauer Rose LLP on

Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more

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