News & Analysis as of

Reporting Requirements Controlled Foreign Corporations

Goodwin

Corporate Transparency Act - Key Points

Goodwin on

Who must report? All US entities created by a filing made with a secretary of state, and all foreign entities registered to do business by the filing of a document with a secretary of state....more

American Conference Institute (ACI)

[Event] 6th National Forum on FOCI - September 20th - 21st, Washington, DC

Hosted by American Conference Institute, the 6th National Forum on FOCI returns for another exciting year with curated programming that provides practical takeaways for managing heightened national security threats for...more

Barnea Jaffa Lande & Co.

EU Proposes to Regulate Companies That Receive Foreign Governments Support – How Will This Affect Foreign and Israeli Companies?

On July 13, 2022, the European Parliament and the European Council agreed on a new regulation concerning “foreign subsidiaries that distort the European market.” Their agreement is the final stage prior to voting on the...more

Miller Canfield

Abraham Accords Alter the Impact of U.S. Antiboycott Laws on Companies Doing Business in the UAE

Miller Canfield on

In September 2020, the United Arab Emirates, Israel and the U.S. signed the Abraham Accords, establishing diplomatic and commercial relations between the UAE and Israel. In August 2020, the UAE issued Federal Decree-Law No. 4...more

Hogan Lovells

Spain: Law 11/2021 implementing ATAD and other measures against fraud

Hogan Lovells on

The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

Eversheds Sutherland (US) LLP

Treasury and the IRS release guidance regarding the repeal of Section 958(b)(4)

The Tax Cuts and Jobs Acts (TCJA) repealed § 958(b)(4) of the Code, which prevented downward attribution of stock ownership from a foreign person to a US person. That repeal has resulted in many foreign corporations being...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

A&O Shearman

Guidance on CFC ‘Downward Attribution Rules’ Provides Limited Relief to US Taxpayers

A&O Shearman on

On October 1, 2019, the Internal Revenue Service (IRS) issued Revenue Procedure 2019-40 (Revenue Procedure) and proposed regulations (Proposed Regulations) addressing issues related to the repeal of section 958(b)(4) by the...more

Proskauer - Not for Profit/Exempt...

Tax-Exempts May Limit Fund Investments Pursuant to New IRS Guidance on UBTI

On August 21, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-67 (the “Notice”), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6) of the Internal Revenue Code (the...more

Foodman CPAs & Advisors

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

Farrell Fritz, P.C.

Reporting A Closely Held U.S. Corporation’s Overseas Activities

Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Foley & Lardner LLP

SEC Proposes Rules on Compensation Clawback Policies

Foley & Lardner LLP on

On July 1, 2015, the Securities and Exchange Commission (SEC) proposed rules relating to compensation clawback policies. The rules, if adopted, would implement the requirements of Section 954 of the Dodd-Frank Wall Street...more

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