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
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
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
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
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 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