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Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

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

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

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

New Tax Law (H.R. 1): Key Highlights Related to Interest Bearing Debt

by Proskauer - Tax Talks on

On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more

Obscure Provision of New Tax Act Complicates Testamentary Tax Planning for Nonresidents with U.S. Beneficiaries

by Charles (Chuck) Rubin on

Nonresidents with a significant portfolio of U.S. stocks typically use a non-U.S. corporation to hold their portfolio. This is because U.S. stocks are generally subject to U.S. estate taxes at the death of their owner, and...more

Spotlight on Alabama: Supreme Court Affirms Limitations of Municipal Business License Tax on Out-of-State Suppliers

by Baker Donelson on

The Code of Alabama grants municipalities certain powers related to the imposition of business license taxes on trades, businesses, or vocations which may be engaged in or carried on in the municipality. This authority is...more

Review/Summary of International Provisions of the New Tax Act

by Charles (Chuck) Rubin on

On December 20, 2017, Congress passed H.R.1, known as the “Tax Cuts and Jobs Act” (referred to in this letter as the “Act”), which was signed into law by President Donald Trump on December 22, 2017. The Act makes widespread...more

Analysis of Key Provisions of the Tax Cuts and Jobs Act

by Ballard Spahr LLP on

As we are sure you know, H.R. 1, informally known as the Tax Cut and Jobs Act, became law on December 22, 2017. This new law will impact almost all taxpayers. Ballard Spahr's Tax Group has prepared a detailed summary of...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

A Concise Summary of the New Tax Law

by Fenwick & West LLP on

This summary describes some of the more significant changes made to U.S. federal tax laws by H.R. 1, the bill signed into law by President Trump on December 22, 2017. Except where otherwise noted, the changes take effect in...more

Main Effects of U.S. Tax Reform on Foreign Taxpayers

by Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Impacts on Foreign Operations That Affects Wholly-Owned and Majority Subsidiaries, And Potentially Minority Owned Stakes As Well

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). The Bill was signed into law by President Trump on December 22. ...more

Tax Reform

On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...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

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

Tax Cuts and Jobs Act: A Summary of Key Components

by Polsinelli on

On December 22, 2017, President Trump signed into law what’s known as the Tax Cuts and Jobs Act. The Act, also sometimes referred to as H.R. 1, contains massive changes to existing tax law the likes of which have not been...more

Impact Of The Tax Bill On International Taxation

The recently issued Conference Bill - the final version of Tax Reform - was approved by Congress on December 20, 2017 and signed into law by President Trump. The brief summary below outlines the sweeping changes in...more

Early Signing of Tax Bill Has Financial Reporting Implications

by Pepper Hamilton LLP on

Last week, President Trump signed H.R. 1 (New Act), the new tax bill amending the Internal Revenue Code to reduce tax rates, modify policies, credits, and deductions for individuals and businesses “to provide for...more

Sweeping U.S. Tax Bill Signed Into Law

by Hogan Lovells on

The provisions of the new tax law – almost all of which go into effect on January 1, 2018 – represent the most significant revisions to the U.S. tax code that have occurred in 30 years. The Act makes sweeping and major...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

Excise Tax Relief for Breweries, Wineries and Distilleries

by McDermott Will & Emery on

The new tax law formerly referred to as the Tax Cuts and Jobs Act of 2017, provides a temporary reduction in alcohol beverage excise taxes for US brewers, winemakers, distillers and beverage importers. Temporary tax relief is...more

Tax Overhaul Draws New Boundaries Around International Business

by Baker Donelson on

The newly passed tax legislation significantly alters the landscape for international business. The final Republican tax cut bill moves the U.S. from a so-called "global taxation regime" to a territorial taxation regime in...more

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

Fifteen Key Provisions in the Final Tax Reform Bill

On December 20, 2017, the Senate and House of Representatives passed H.R. 1, known as the “Tax Cuts and Jobs Act” (“Tax Reform Bill”). President Trump is expected to sign the Tax Reform Bill by early January. The 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

How Tax Reform Could Trigger Significant Taxes For Unwary Stockholders (And Funds) In Foreign Companies

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). - Statutory language of the Bill may cause an unexpected tax hit on unwary U.S. stockholders who...more

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