Repatriation

News & Analysis as of

Tax Reform in the New Administration

The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...more

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

Is Tax Reform On the Horizon?

2017 will bring Republican control to D.C. It will also potentially bring tax reform. Both President Elect Donald Trump and House Republicans have proposed sweeping changes to the U.S. tax system, which we have briefly...more

What Trump’s Tax Plan Means For Canada

The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely. The specifics of that reform are not known but the...more

Post-Election Update 2016

The 2016 election results have significant implications for companies across a wide range of industry sectors. From environmental policy to financial services to tax reform, President-elect Trump has committed to sweeping...more

[Webinar] Post-Election Webinar - November 9th - 11:00a.m. EST

As the dust settles after the presidential candidates’ first debate, BakerHostetler’s Federal Policy team continues to analyze the impact of the 2016 election on federal policy issues. After all the votes are counted, please...more

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

New Law on Tax and Social Security Premium Amnesty in Turkey

On August 3, 2016, Turkey passed a detailed new law entitled "Statutory Proposal on Restructuring of Certain Receivables" (the "Law") which offers taxpayers a broad amnesty for most types of unpaid taxes and for unpaid social...more

Farewell to Ralph Stanley and a Success in Repatriation

Yesterday I honored Scotty Moore, the lead guitarist for Elvis Presley, who died last week. Today I want to pay homage to another equally large giant from the world of music who recently died, Ralph Stanley. Stanley,...more

Brexit Headline Checklist

This checklist is designed to set out some of the key questions which businesses will need to consider in their initial planning phase as they evaluate their existing structures and operations and the potential impact of...more

Doing business in the Ras Al Khaimah Free Trade Zone

Major benefits of incorporating inside a free trade zone, as opposed to on the UAE’s mainland. However, in brief the companies are entitled to 50 years of zero corporate tax while still being entitled to repatriate the...more

Doing business in the Dubai Airport Freezone

Major benefits of incorporating inside a free trade zone, as opposed to on the UAE’s mainland. However, in brief the companies are entitled to 50 years of zero corporate tax while still being entitled to repatriate the...more

Doing business inside the UAE’s freezones

If you are considering establishing a business in the UAE, you would be wise to spend time investigating the various idiosyncrasies of the local market. One of the first decisions you will arrive at is where to base your...more

Brazil: newly issued regulations from tax authorities on the tax and currency exchange voluntary disclosure and amnesty program

This article is aimed at assisting Brazilian tax residents, mainly individuals, interested in learning more about the current tax and currency exchange voluntary disclosure and amnesty program (RERCT) established in Law No....more

Looking Over the Edge of the Cliff– The Use of Pooled Income Funds for the Repatriation of Offshore Carried Interest

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

Latin America Alert: Brazil's Repatriation Law Introduces Tax and Currency Exchange Voluntary Disclosure and Amnesty Program – Top...

Brazil has passed Law No. 13,254, the Repatriation Law, introducing a tax and currency exchange voluntary disclosure and amnesty program (locally known by the acronym RERCT) to stimulate the voluntary disclosure of assets,...more

Investing in Morocco

Over recent years, Kingdom of Morocco has created a legal and regulatory framework very attractive for foreign investors. In addition to its political stable environment, a recent series of tax treaties with numerous...more

Energy Newsletter - October 2015

FERC Shares Best Practices for Stakeholder Outreach in Gas Project Permitting - The dramatic increase in domestic energy production over the past several years has resulted in the involvement of the Federal Energy...more

[Webinar] Tax Planning for Investments Into Brazil - Oct. 14th, 12:00pm ET

Please join us on Wednesday, October 14th at 12:00pm EST for an in-depth joint presentation by tax attorneys, Jeffrey Rubinger of Bilzin Sumberg and Fernando Martins of WFaria Advogados on the cross-border tax considerations...more

Angola's New Private Investment Law

On 11 August 2015, Angola's New Private Investment Law ("NPIL") came into force on its publication in Angola's Gazette, repealing the previous 2011 law. Like its predecessor, the NPIL sets out the rules applicable to...more

CFPB Obtains Injunction Against World Law Group

The CFPB recently obtained preliminary injunctions against debt-reduction company World Law Group, its affiliates and its owners, thereby freezing the company’s assets and stopping all further operations pending the outcome...more

Successful Strategies for Doing Business in Asia: Taiwan (Updated)

WHAT ROLE WILL THE GOVERNMENT OF TAIWAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Three types of Taiwan government approval requirements may be relevant to direct foreign investment in Taiwan: •...more

Successful Strategies for Doing Business in Asia: Singapore (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF SINGAPORE PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? REGISTRATION REQUIREMENT - Save for the restrictions discussed under Question 5, there is generally no...more

Successful Strategies for Doing Business in Asia: Philippines

WHAT ROLE WILL THE GOVERNMENT OF THE PHILIPPINES PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The following Philippine government agencies are involved in approving and/or regulating foreign direct...more

New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

Earlier this week the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations...more

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