News & Analysis as of September 23, 2024

Income Taxes › Required Documentation

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative

McDermott Will & Emery on 6/17/2022

The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more

Section 385 Treasury Regulations Developments

A&O Shearman on 11/5/2019

Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

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

Latham & Watkins LLP on 4/21/2016

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

Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes

Eversheds Sutherland (US) LLP on 4/8/2016

On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations) that are intended to combat perceived concerns associated with indebtedness between...more

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on 7/15/2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

IRS Draft of 2013 Form 990 and Instructions

Proskauer - Not for Profit/Exempt... on 12/20/2013

Earlier this year the IRS issued drafts of the 2013 Form 990, Return of Organization Exempt From Income Tax, and 2013 Form 990 Instructions. Although there were no major changes to the Form 990, there were several changes and...more

China SAT Releases Bulletin on CIT Treatment of Non-resident Enterprises' Secondment Arrangement

Sheppard Mullin Richter & Hampton LLP on 6/4/2013

China’s State Administration of Taxation (“SAT”) released Bulletin [2013] No. 19, “Announcement on Issues Concerning Levying Corporate Income Tax on Services Provided by Non-residents through Seconding Personnel to China”...more

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