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The U.S. Tax Cuts and Jobs Act: Fundamental Changes to Business Taxation

by Jones Day on

Signed into law December 22, 2017, the "Tax Cuts and Jobs Act" represents the most comprehensive reform to the U.S. federal tax code in a generation. The Act's most notable provisions include significant reductions in both...more

UK charities seeking opinions on their equivalency to US tax-exempt charities

by DLA Piper on

On 2 October 2017, the IRS provided guidance to US tax advisers for issuing opinions to the effect that a non-US charity is equivalent to an analogous tax-exempt US charity (Rev. Proc. 2017-53, 2017-40 IRB 263). Few non-US...more

Kyiv Tax Newsletter (Ukrainian) #2

by Dentons on

On 27 December 2017, the Cabinet of Ministers of Ukraine approved, by its Order No. 1045, the List of states (territories), which comply with the criteria set in paragraph 2) of subsection 39.2.1 (Section 39.2 of Article 39...more

Kyiv Tax Newsletter - January 2018 #2

by Dentons on

The Cabinet of Ministers revised the list of low-tax jurisdictions for the purposes of transfer pricing - On 27 December 2017, the Cabinet of Ministers of Ukraine approved, by its Order No. 1045, the List of states...more

US Tax Reform Measures Affecting Foreign Multinationals

by McDermott Will & Emery on

On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

by Latham & Watkins LLP on

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

New Tax Changes: The Tax Cuts And Jobs Act

by Roetzel & Andress on

The Tax Cuts and Jobs Act (“Act”) (P.L. 115-97) signed into law by President Trump on December 22, 2017 and effective for tax years starting January 1, 2018 reflects a compromise between the House and Senate Bills as...more

Businesses face unlimited fines for failure to prevent facilitation of tax evasion

by Womble Bond Dickinson on

Introduction - As part of a global crackdown on tax evasion, the Criminal Finances Act 2017 (the Act) introduced a new offence. From 30 September 2017, an organisation commits a criminal offence if an employee or...more

Tax Cuts and Jobs Act could have significant impact on structuring of US and foreign investments

by DLA Piper on

The Tax Cuts and Jobs Act (the New Tax Law), signed into law in late December by President Donald Trump, makes major permanent and temporary changes to the US federal tax system. The changes will have a significant impact on...more

China defers 10 percent withholding tax on dividend income reinvested into Encouraged Industries

by DLA Piper on

Prior to 2008, foreign investors were generally exempt from withholding income tax on dividend income derived from their investment in China under the prior PRC Enterprise Income Tax Law for Foreign Invested Enterprises and...more

Kyiv Tax Newsletter (Ukrainian) - January 2018

by Dentons on

On 11 December 2017, the Ministry of Finance of Ukraine introduced its Road Map for the implementation of international standards of transparency and exchange of information for tax purposes....more

Kyiv Tax Newsletter - January 2018

by Dentons on

The Ministry of Finance of Ukraine elaborated its Road Map for the implementation of international standards of transparency and exchange of information for tax purposes - On 11 December 2017, the Ministry of Finance of...more

Tax Act: Vote and Value

by Alston & Bird on

Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations. One of the new Tax Cuts and Jobs Act’s changes to Subpart F...more

Australian Government releases hybrid mismatch rules to counteract entities exploiting differences in the taxation treatment of an...

by DLA Piper on

Introduction and overview - The Australian Treasurer, the Hon Scott Morrison MP, on Friday 24 November, released exposure draft legislation to prevent entities that are liable to Australian income tax from avoiding income...more

UK Tax Round Up - December 2017

by Proskauer Rose LLP on

Finance (No. 2) Bill 2017-19 - The first version of the Finance (No. 2) Bill 2017-19 was published on 1 December 2017. The majority of the Bill's content had been previously announced at the Autumn 2017 Budget (see...more

New Tax Law Provides Relief for Retailers, Who Successfully Lobbied for Reform

by Bryan Cave on

The new tax law signed by President Trump today is the broadest rewrite of federal tax law in three decades and will have a widespread impact for retailers. The legislation is generally effective for taxable years beginning...more

U.S. Tax Reform Bill Passes Both Houses; Awaits President's Signature

by Morrison & Foerster LLP on

On December 20, 2017, both the House and the Senate passed H.R. 1 (the “Bill”), which President Trump is expected to sign by January 3, 2018. The Bill dramatically alters the U.S. approach to domestic and international...more

Congress Passes Tax Reform Legislation, Implementation Imminent

by Latham & Watkins LLP on

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

IRS Issues Limited Section 409A Relief to Pay Income Taxes on Pre-2009 Section 457A Deferrals

by Proskauer - Tax Talks on

The Internal Revenue Service (the “IRS”) has issued Notice 2017-75 (the “Notice”), which provides certain limited relief from the strict requirements of Section 409A of the Internal Revenue Code of 1986, as amended (the...more

U.S. Tax Reform – Key Highlights for Private Investment Funds in Tax Cuts and Jobs Act Bill

by Proskauer Rose LLP on

On Friday, December 15, 2017, the Congressional conference committee released a revised version of the Tax Cuts and Jobs Act (the "Tax Bill"). The Senate and the House are expected to vote on the Tax Bill this week. The Tax...more

Following the Senate’s Lead – The International Tax Provisions in the Final Bill

On December 15, 2017, the House-Senate Conference Committee released a revised version of the Tax Cuts and Jobs Act (the Final Bill) that is expected to be passed by the House of Representatives and Senate later this week and...more

Congress Passes Tax Cuts and Jobs Act

On December 20, 2017, the House and Senate approved H.R. 1, the "Tax Cuts and Jobs Act" (the "Act").1 This approval follows reconciliation by a conference committee of the original legislation passed by the House on November...more

US prosecutors seek tenfold increase in offshore evasion sentences

by Sanford Millar on

A conviction for failure to report offshore financial account now carries a far greater risk of a lengthy prison term according to Mark Daly, senior litigation counsel at the U.S. Department of Justice. US prosecutors seek...more

Proposed Tax Regulations Address International Aspects of the New Partnership Audit Regime

by Alston & Bird on

We are about to witness an almost unprecedented centralized partnership audit regime that takes full effect for taxable years starting on or after January 1, 2018, as adopted in late 2015 by Section 1101 of the Bipartisan...more

State Aid in Disguise?—EC Investigates UK Tax Regime

by Jones Day on

The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more

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