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
Beginning in 2023, an excise tax of 1% will apply to public company stock buybacks and a 15% corporate minimum tax generally will apply to corporations with book income exceeding $1 billion.
Key Points:
..Public...more
8/22/2022
/ Acquisitions ,
Alternative Minimum Tax ,
Corporate Taxes ,
Derivatives ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
Mergers ,
Multinationals ,
Publicly-Traded Companies ,
Share Buybacks ,
Share Classes ,
Special Purpose Acquisition Companies (SPACs) ,
Stock Options ,
Stock Repurchases
The agreement builds on the two-pillar approach outlined by the OECD and aims to tackle the challenges arising from an increasingly globalized and digital economy.
Key Points:
..Under Pillar One, the largest and most...more
Volatile trading markets and economic instability may prompt taxpayers to modify, purchase, or repurchase debt; participants should consider the tax consequences.
Key Points:
..Issuers may incur immediate income in the...more
The 31 December deadline for EU Member States to adopt implementing legislation for DAC 6 is fast approaching. Intermediaries and taxpayers must be ready for compliance.
By the end of 2019, each Member State of the...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Final bill retains key aspects of House and Senate proposals with some surprise last-minute modifications.
Key Points:
..The bill adopts, with some modifications, earlier US House and Senate tax reform...more
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details.
On September 27, a group of Trump Administration and Congressional leaders...more
The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations.
On July 28, 2017, the US Department of the Treasury (Treasury) and...more
Administration and Congressional tax negotiators abandon border adjustment tax, but leave unanswered questions regarding rates, revenues, and taxation of US multinationals.
As Congress heads toward its late summer 2017...more
Decision could open planning opportunities for non-US partners regarding sale of a partnership interest.
The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more
Tax reform plans would fundamentally alter the landscape for key business decisions, impacting a business’ legal, finance, corporate development and other divisions, as well as tax groups.
Key Points:
..Tax reform...more
New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions.
On October 4, 2016, the Internal Revenue Service (IRS)...more
Seeking to curb “excessive” use of related-party debt, Treasury and IRS retain basic framework, but significantly narrow the scope, of the Proposed Regulations.
On October 13, 2016, the US Department of the Treasury...more
Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures.
On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax
Congress extends tax credits for wind and solar energy projects, but will phase the credits out over several years.
The Consolidated Appropriations Act, 2016 (the Act), which President Obama signed into law on December...more
Legislation impacts tiered partnerships and M&A transactions. Existing partnerships should review operating agreements before new rules take effect.
The Bipartisan Budget Act of 2015 (the Act), which President Obama...more
By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques.
A pair of revenue rulings the US Internal Revenue Service (IRS)...more