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Required Documentation Corporate Taxes

McDermott Will & Emery

“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative

McDermott Will & Emery on

The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more

Foley & Lardner LLP

Attention Taxpayers: New IRS Rules May Deem Debt to Be Stock

Foley & Lardner LLP on

In April, the IRS proposed rules that would treat debt between related corporations as stock for U.S. tax purposes. These rules would apply to all corporations (including regular C corporations, S corporations, foreign...more

Baker Donelson

New "Inversion" Proposed Regulations Inspired By The Pfizer/Allergan Deal May Impact Corporate Tax Planning Strategies

Baker Donelson on

The Treasury Department has recently promulgated proposed regulations dealing with so-called inversion transactions. Inversion transactions are ones in which a U.S. corporation changes its domicile to a nation with a more...more

Foley & Lardner LLP

IRS Rules Could Treat Related Party Debt as Stock

Foley & Lardner LLP on

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

McDermott Will & Emery

Focus on Tax Controversy - Summer 2015

McDermott Will & Emery on

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Dechert LLP

Transfer Pricing: Major Developments for Certain French Companies Engaging in Transactions with Related Entities

Dechert LLP on

The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies. New Provisions of French Law - Provisions Already Adopted - Within the...more

Sheppard Mullin Richter & Hampton LLP

China SAT Releases Bulletin on CIT Treatment of Non-resident Enterprises' Secondment Arrangement

China’s State Administration of Taxation (“SAT”) released Bulletin [2013] No. 19, “Announcement on Issues Concerning Levying Corporate Income Tax on Services Provided by Non-residents through Seconding Personnel to China”...more

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