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Offshore Companies Corporate Taxes

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

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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

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

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Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Orrick, Herrington & Sutcliffe LLP

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...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

Orrick, Herrington & Sutcliffe LLP

IRS Extends Date for Section 965 Liability Transfer Agreement

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

Jones Day

Treasury Provides Details on Transition Tax

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Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform. On August 1, 2018, proposed...more

Butler Snow LLP

Section 965 Proposed Regulations Issued

Butler Snow LLP on

On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a...more

Kelley Drye & Warren LLP

Corporate Inversions

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

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