News & Analysis as of

Safe Harbors Corporate Taxes

Alston & Bird

Seeking Shelter in Your International Tax Safe Harbors, Even if They Are Temporary

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Our International Tax Group provides an overview of a pair of safe harbors the Organisation for Economic Cooperation and Development has provided for large multinational enterprises during the transition to the Pillar 2...more

McDermott Will & Emery

Weekly IRS Roundup February 13 – February 17, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 13, 2023 – February 17, 2023. ...more

Latham & Watkins LLP

Treasury and IRS Issue Initial Guidance on Stock Buyback Tax and Corporate Minimum Tax

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New guidance clarifies certain key points on implementing the 1% tax that generally applies to public company stock buybacks and the 15% corporate minimum tax that generally applies to corporations with book income exceeding...more

Eversheds Sutherland (US) LLP

They have arrived: New York issues “final draft” corporate income tax apportionment regulations

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after...more

Goodwin

Luxembourg: New Rule Disallowing Deduction On Payments To EU Non-cooperative Countries

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Luxembourg has introduced new legislation disallowing the deduction of interest and royalties owed by Luxembourg corporate taxpayers to associated enterprises established in a jurisdiction included in Annex I of the European...more

Foster Garvey PC

The CAT Is Clearly Ruling the Roost in Oregon – It Is Occupying a Large Amount of Time for Tax Practitioners This Busy Season

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Temporary Rules Keep Rolling in - The Oregon Department of Revenue (the “Department”) recently issued four new temporary rules relative to the Oregon Corporate Activity Tax (the “CAT”). The new rules went into effect on...more

Robins Kaplan LLP

Financial Daily Dose 2.10.2020 | Top Story: Volvo May go Public Via Merger With Owner’s Geely Automobile Holdings

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Volvo’s owner, Li Shufu, is mulling over a move to combine the carmaker with his publicly traded Geely Automobile Holdings—a play that would take Volvo public and “unify the bulk of billionaire Li’s growing stable of...more

Robins Kaplan LLP

Financial Daily Dose 2.3.2020 | Top Story: Boeing’s 737 MAX Aircraft Face Continued Problems

Robins Kaplan LLP on

Boeing Co.’s 737 MAX aircraft face continued problems from “potentially hazardous wiring.” European regulators want the manufacturer to relocate some of the wiring to prevent “potential short circuit[s], which in a worst-case...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 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 December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...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

A&O Shearman

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

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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 - Tax Talks

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

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On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

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While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

Brownstein Hyatt Farber Schreck

Taxation & Representation - September 24, 2018

TAX TIDBIT - With the midterm elections just weeks away, both parties have been hitting the campaign trail hard, strutting their stuff to win over voters. ...more

Miller Canfield

IRS Safe-Harbor to Calculate Federal Income Tax Credits for Research Expenses

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A taxpayer may claim a credit against its federal income tax liability for research expenses paid or incurred during the tax year. The definitions of research expenses for financial reporting purposes and federal income...more

Foley & Lardner LLP

The GOP’s Tax Cuts and Jobs Act Includes Changes Impacting the Renewable Energy Industry

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On November 3rd, House Ways and Means Committee Chairman Kevin Brady (R. Tex.) released the “chairman’s mark” to H.R. 1, the “Tax Cuts and Jobs Act” (TCJA). The TCJA represents the most extensive rewrite of the Internal...more

Miles & Stockbridge P.C.

IRS Issues New Guidance on TIGER Grants

In Revenue Procedure 2017-22, the IRS clarified earlier guidance regarding safe harbors for corporate taxpayers receiving grants from the government for capital improvements to transportation services. Section 118...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 2

State Tax Department Releases New Draft Article 9-A Combined Reporting Regulations - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

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For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

McDermott Will & Emery

IRS Updates EPCRS Correction Methods and Procedures

Reflecting comments it requested, and others it received, the Internal Revenue Service (IRS) recently issued two updates which modify the Employee Plans Compliance Resolution System (EPCRS), which is the comprehensive system...more

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