News & Analysis as of

Repatriation

Trump Administration Announces Outline of Its Tax Proposal

by Proskauer - Tax Talks on

Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

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

Newsletter Corporate - February 2017

M&A - Balance Sheet Guarantees: German case law has recently developed new requirements for drafting Balance Sheet Guarantees in Share Purchase Agreements. If not properly drafted, such Balance Sheet Guarantees may be...more

Cuban Refugees Are Waiting at the Border

by Jackson Lewis P.C. on

Many Cubans who were making the long and dangerous trek through jungles and other countries to the United States before the inauguration of President Donald Trump on January 20 are waiting at the U.S. border for word from the...more

The IRS Targets Thirteen Issues in Its New Compliance Campaigns

by Ropes & Gray LLP on

On Tuesday, January 31, the IRS announced the rollout of thirteen initial compliance campaigns that will be undertaken by its Large Business and International Division (“LB&I”). These campaigns are part of a broader IRS...more

Key Takeaways: Inside the White House and Capitol Hill — The Impact of a New Administration on Global Markets

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

End of Immigration Privileges for Cuban Nationals Signals Changes in U.S.-Cuba Relationship

by Holland & Knight LLP on

Before former President Barack Obama left office, one of his last acts was to repeal the policy granting asylum to every Cuban national who made it to the United States. As part of the normalization of formal diplomatic...more

First LB&I Campaigns Demonstrate a Flexible Approach

On January 31, 2017, the Large Business & International Division of the IRS (LB&I) released the subjects of its first 13 campaigns. Each campaign addresses a specific area that the IRS has identified as a substantial...more

ICE’s Other Job: Recovering and Repatriating Cultural Property

by Jackson Lewis P.C. on

ICE, primarily known for its immigration enforcement efforts and raids, does much more than that. The Homeland Security Investigations Unit (HSI) of ICE has announced the repatriation of more than 400 Peruvian...more

Mexico 2017 Repatriation Tax Amnesty

by White & Case LLP on

A new amnesty program to incentivize the repatriation of funds kept abroad by Mexican taxpayers was launched. The program will be open until mid-2017 and participants would be obliged to comply with specific requirements,...more

President Trump Has Been Inaugurated. What's Next for Tax Reform?

by Baker Donelson on

President Donald J. Trump has just been inaugurated as the 45th President of the United States and his proposals regarding tax reform played a key role throughout his entire presidential campaign. Because Republicans retained...more

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

by Seyfarth Shaw LLP on

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?

by Butler Snow LLP on

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

by Bennett Jones LLP on

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

by Bracewell LLP on

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

by BakerHostetler on

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...

by Gerald Nowotny on

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

by White & Case LLP on

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

by Thomas Fox on

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

by White & Case LLP on

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

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

by DLA Piper on

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

by Gerald Nowotny on

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...

by DLA Piper on

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

by DLA Piper on

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

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