Key Points -
- Many of the tax reform suggestions President-elect Trump floated during the campaign would result in significant revenue loss, which could mean they will face resistance from Republicans concerned about...more
1/21/2025
/ Budget Reconciliation ,
Corporate Taxes ,
Debt ,
Deficit Reduction ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Legislative Agendas ,
Regulatory Agenda ,
Renewable Energy ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration
On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more
Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more
The OECD envisioned a coordinated rollout of Pillar Two, its model of interlocking rules to establish a global minimum corporate tax rate.
However, the staggered implementation taking place among participating...more
In legislative text released October 28, 2021, the House Rules Committee proposed to impose a 1% excise tax on stock repurchases by publicly traded companies starting in 2022. If the provision is enacted, corporations will...more
The G7’s support for OECD-backed tax reforms could mark a big step toward a more consistent, revamped global tax scheme — depending on the details and whether it is actually adopted. ...more
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
6/15/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Energy Tax Incentives ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Issues ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
Former Vice President Joseph Biden has proposed a number of fundamental changes to the tax code over the course of his campaign. If he is elected president and if the Democrats keep control of the House of Representatives and...more
9/24/2020
/ Alternative Minimum Tax ,
Capital Gains ,
Capital Gains Tax ,
Corporate Taxes ,
Estate Tax ,
GILTI tax ,
Joe Biden ,
Like Kind Exchanges ,
Offshore Funds ,
Presidential Elections ,
Retirement Plan ,
Social Security Taxes ,
Tax Credits ,
Tax Policy ,
Tax Rates ,
Tax-Deferred Exchanges
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more
4/2/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
CARES Act ,
Controlled Foreign Corporations ,
Coronavirus/COVID-19 ,
Debt Restructuring ,
EBITDA ,
GILTI tax ,
High-Yield Markets ,
Interest Income ,
International Tax Issues ,
Net Operating Losses ,
Relief Measures ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Relief
On March 27, 2020, Congress approved the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) to provide financial assistance to individuals and businesses, which in aggregate greatly exceeds the financial package...more
3/31/2020
/ Airlines ,
Banks ,
Capital Markets ,
CARES Act ,
Commercial Tenants ,
Community Banks ,
Coronavirus/COVID-19 ,
Economic Stimulus ,
Families First Coronavirus Response Act (FFCRA) ,
Federal Food Drug and Cosmetic Act (FFDCA) ,
Federal Grants ,
Federal Loans ,
Federal Reserve ,
Food and Drug Administration (FDA) ,
Forbearance Agreements ,
Foreclosure ,
Health Care Providers ,
Health Insurance ,
Landlords ,
Life Sciences ,
Medical Devices ,
Mergers ,
Mortgages ,
National Security ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Personal Protective Equipment ,
Pharmaceutical Industry ,
Prescription Drugs ,
Property Owners ,
Qualified Immunity ,
Relief Measures ,
Small Business ,
Small Business Loans ,
Supply Chain ,
Tax Credits ,
Tax Deductions ,
Tax Deferral ,
Tenants ,
Unemployment Insurance ,
Virus Testing
The U.S. Supreme Court upended 51 years of precedent on Thursday, June 21, 2018, when it held in a 5-4 decision that a state can require an online retailer with no in-state property or personnel to collect and remit sales tax...more
6/22/2018
/ Appeals ,
Commerce Clause ,
Constitutional Challenges ,
Internet Retailers ,
Interstate Commerce ,
Out-of-State Companies ,
Physical Presence Test ,
Popular ,
Quill ,
Reversal ,
Sales & Use Tax ,
SCOTUS ,
South Dakota v. Wayfair ,
Substantial Nexus
On May 23, 2018, the Department of the Treasury and the Internal Revenue Service (IRS) issued Notice 2018-54, stating that proposed regulations will be issued addressing the deductibility of certain payments made by taxpayers...more
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
Reorganizations ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions
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
2/28/2017
/ Business Taxes ,
Capital Markets ,
Corporate Taxes ,
DBCF Tax ,
Exports ,
Foreign Earned Income ,
Imports ,
International Tax Issues ,
Legislative Agendas ,
Multinationals ,
Offshore Funds ,
Repatriation ,
Tax Reform ,
Trump Administration ,
Value-Added Tax (VAT) ,
WTO
On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more
On June 9, 2015, the city of Chicago released two rulings that significantly expand the city’s 9 percent gross receipt tax to charges for cloud computing and other services delivered over the Internet. The first ruling (City...more
On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more
On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented this release on March...more