News & Analysis as of

Foreign Corporations Tax Treaty

Eversheds Sutherland (US) LLP

Congress considers TCJA extenders and Taiwan tax relief

In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...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

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

Holland & Knight LLP

2023 Mexican Tax Considerations for Mexican and Foreign Taxpayers

Holland & Knight LLP on

Although no major tax reform was adopted in Mexico as part of the 2023 Economic Package, changes at an international level and some being brought at the regulatory level could have significant implications for different...more

Freeman Law

Navigating the Branch Profits Tax

Freeman Law on

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

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

Wilson Sonsini Goodrich & Rosati

Corporate Tax 2019 - Seventh Edition - USA Chapter

Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more

Proskauer Rose LLP

Tax Round Up - April 2017

Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Bilzin Sumberg

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

Bilzin Sumberg on

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

International Crackdown: Tax Authorities Look to Employment Structures in Initiating Audits

In structuring their workforces abroad, taxes are a major driving force for employers—and if recent government initiatives are any indicator, employers should take care when considering the tax implications of their staffing...more

Bilzin Sumberg

Change in the UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

Bilzin Sumberg on

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Delaware LLCs - The Implications of Anson"

Skadden held a webinar on September 14, 2015, to discuss certain key aspects of the U.K. Supreme Court decision in Anson v. HMRC, with a focus on potential ramifications for multinational groups including Delaware LLCs (and...more

Patterson Belknap Webb & Tyler LLP

Entering the U.S. Without Entering Its Tax System: Holding Company Structures for U.S. Operations

Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits...more

Bilzin Sumberg

Use of Estonia in U.S. International Tax Planning

Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

Bilzin Sumberg

Retroactive Tax Planning

Bilzin Sumberg on

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

Bilzin Sumberg

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Bilzin Sumberg on

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Bilzin Sumberg

Foreign Investment In The U.S. Through Romania Just Became More Interesting

Bilzin Sumberg on

All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision. The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining...more

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