President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more
Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more
Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more
2017 tax reform efforts may alleviate adverse deemed dividend tax treatment of foreign subsidiary support for the obligations of U.S. parent companies. Present support is limited to the pledge of 66 ?rds of the stock in...more
The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more
On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more
On January 25, 2017, Skadden hosted a panel discussion at the London Stock Exchange on the potential policy direction of the Trump administration. The panel touched on tax reform, trade agreements, inbound and outbound U.S....more
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
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
U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more