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Tax Deductions International Tax Issues

Cadwalader, Wickersham & Taft LLP

Liberty Global Appeals Economic Substance Doctrine Ruling

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

Cadwalader, Wickersham & Taft LLP

A Toothless Tax Avoidance Scheme: M Northwood v HMRC

The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more

Freeman Law

International Tax Concepts: Dual-Status Taxpayers

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A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

Cadwalader, Wickersham & Taft LLP

HMRC v BlackRock Holdco 5 LLC Throws a Spotlight on UK Transfer Pricing and the ‘Unallowable Purposes’ Rule

A decision in late-July 2022 of the UK’s Upper-tier Tax tribunal (“UTT”) has held that interest recognized by a UK resident company on loan notes issued to its parent was non-deductible under the UK transfer pricing rules, as...more

Kramer Levin Naftalis & Frankel LLP

Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Blake, Cassels & Graydon LLP

Budget fédéral de 2022 – Présentation de certaines mesures fiscales

Le 7 avril 2022 (le « jour du Budget »), la ministre des Finances du Canada a présenté le budget fédéral de 2022 (le « Budget 2022 »). Certains contribuables ont peut-être été soulagés de constater que le Budget 2022 ne...more

Blake, Cassels & Graydon LLP

2022 Federal Budget: Selected Tax Measures

On April 7, 2022 (Budget Day), the Minister of Finance introduced Canada’s 2022 Federal Budget (Budget 2022). While taxpayers may be relieved that Budget 2022 does not include an increase to the capital gains inclusion rate...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

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UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Hogan Lovells

Obligaciones para Organizaciones de la Sociedad Civil 2022

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Durante el 2022 debemos contemplar ciertas obligaciones en este año así como nuevas disposiciones de interés para las OSC en diversas materias. Es importante que las revises para que cumplas con todos los requisitos que pide...more

Miller Nash LLP

Today in Tax: Eligibility of Electronic Services Income for FDII Deduction

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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more

Brownstein Hyatt Farber Schreck

Taxation & Representation, December 14, 2021

Senate Finance Committee Democrats Update Build Back Better. On Saturday afternoon, Senate Finance Committee Chair Ron Wyden (D-OR) released legislative text for the committee’s portion of the Build Back Better Act. The text...more

Orrick, Herrington & Sutcliffe LLP

Super deduzione per i costi di R&S e credito d’imposta – le novità del Decreto Fiscale

È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more

Orrick, Herrington & Sutcliffe LLP

Super Deduction for R&D Costs and Tax Credit - What's New in the Tax Decree

The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...more

Proskauer Rose LLP

UK Tax Round Up - October 2021

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The Chancellor presented the Budget on 27 October. Although it contained a wide range of general spending and tax-related announcements, there was nothing of significance for the private funds industry that had not been...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, October 26, 2021

Negotiations Update. After months of negotiation, Democrats appear close to an agreement between the White House, progressives and influential moderate Sens. Joe Manchin (D-WV) and Kyrsten Sinema (D-AZ) on budget...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, October 5, 2021

TAX TIDBIT - Where In the Tax World Are Manchin and Sinema? The contents and scope of the Build Back Better Act—the budget reconciliation measure through which congressional Democrats are attempting to enact most of...more

Freeman Law

The Tax Court in Brief - September 2021 #2

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Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

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In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Freeman Law

The Tax Court in Brief - August 2021 #4

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more

Skadden, Arps, Slate, Meagher & Flom LLP

Biden Administration’s Green Book Proposes Significant Changes to Tax Regime

On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more

Freeman Law

The Tax Court in Brief - January 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Freeman Law

The Tax Court in Brief - November 2020

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

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