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Jurisdiction Corporate Taxes

Walkers

15% Global Minimum Tax Rate: Draft Legislation lodged in Jersey

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Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Eversheds Sutherland (US) LLP

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Allen Barron, Inc.

New Corporate Tax Increase Proposal and Focused IRS Audits - Is the Cost of Business Going Up?

Allen Barron, Inc. on

The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Eversheds Sutherland (US) LLP

Bermuda corporate income tax consultation: impact on reinsurance agreements

Bermuda has announced that it is considering the implementation of a new corporate income tax regime to be effective on or after January 1, 2025, in response to the OECD’s BEPS Pillar II global minimum tax rules. The...more

Hogan Lovells

Spain releases its long awaited draft list of non-cooperative jurisdictions

Hogan Lovells on

On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more

Morrison & Foerster LLP

German Federal Fiscal Court Deciding on Unjustified Discrimination of Non-EU Pension Funds

Under the German Corporate Income Tax Act (Sec. 32 para. 1 no. 2 German Corporate Income Tax Act, KStG), in the case of dividend payments, non-EU pension funds—unlike local pension funds—do not have the right to claim a...more

Conyers

Bermuda Registrar of Companies New Registry System: Impact on Economic Substance Declaration Portal

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The Bermuda Registrar of Companies (RoC) has advised that it will be launching the first phase of its new company registry system on 7 June 2021. Economic Substance Declarations that have been started must be finished and...more

Goodwin

COVID-19: Tax Residence Status of Companies

Goodwin on

The global impact of the novel coronavirus (COVID-19) is leading to unprecedented changes in working practices. In particular, travel restrictions and, in many cases, border closures are already causing, and will continue to...more

Latham & Watkins LLP

Corporate Reorganisations 2019

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‘Corporate reorganisation’ is something of an umbrella term, and is used in many different contexts to mean a multitude of different things. At one extreme, a reorganisation may refer to ‘paper’ changes to a corporate group’s...more

Orrick, Herrington & Sutcliffe LLP

New Offshore Economic Substance Rules Could Spell Significant Concern for PE Funds and Bermuda/Cayman/BVI-Based Structures

Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more

Katten Muchin Rosenman LLP

OECD Publishes Initial Recommendations on BEPS

On September 16, the Organisation of Economic Co-operation and Development (OECD) published a set of recommendations for a coordinated approach to fight tax avoidance by multinational enterprises under the Base Erosion and...more

Mintz

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

Mintz on

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

Morrison & Foerster LLP

‘Inherited’ Nexus And Other Extreme Nexus Theories

Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more

Allen Matkins

Like Elmer Gantry, Supreme Court Breathes New Life Into Revivals

Allen Matkins on

The state, of course, likes to see corporations pay their taxes. When a corporation fails to do so, “the corporate powers, rights and privileges of a domestic taxpayer may be suspended, and the exercise of the corporate...more

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