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International Trade Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.

IRS Issues Guidance for New Repatriation Tax

Many U.S. owners of foreign companies are surprised to hear that the new repatriation tax not only applies to “repatriated” foreign earnings, but also to foreign earnings that are not repatriated into the U.S. They are even...more

New U.S. Tax Law Leaves Non-U.S. Person Estate Tax Intact

by Jones Day on

Prior to the passage of the Trump Administration's new tax bill, many had speculated on two key possible impacts for non-U.S. person private wealth bank and brokerage clients—the elimination of the estate tax exemption...more

Tax Reform: Key Considerations for M&A, Private Equity & Venture Capital Transactions

by Morrison & Foerster LLP on

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the “Act”). The Act was ostensibly promoted as a means to encourage investment and to promote growth in the U.S. economy, while reducing harmful...more

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

Disposition of a Partnership Interest Now Subject to Tax Withholding

by K&L Gates LLP on

The new Tax Cut and Jobs Act of 2017 (the “Act”) contains a provision that is of great importance to any persons buying or selling an interest in a partnership. New Section 864(c)(8) of the U.S. Internal Revenue Code (the...more

New Partnership Audit Regulations Released as Permitting Push-Out Election Through Tiered Partnerships

by Ropes & Gray LLP on

In a trilogy of releases in the last six weeks, the Department of Treasury (“Treasury”) provided much-needed guidance on the implementation of the partnership audit rules in the Bipartisan Budget Act of 2015 (the “BBA...more

Update on IRS Offshore Initiatives: Investigations and agreements with financial institutions worldwide

by Moskowitz LLP on

In our last post, we noted that the U.S. government goes to great lengths to identify and prosecute noncompliant taxpayers, as well as promoters and financial institutions who assist U.S. taxpayers avoid their tax obligations...more

EU Tax Haven Blacklist Update

by Ropes & Gray LLP on

The unveiling of the EU tax haven blacklist was covered in our Alert dated 12 December, 2017. While the consequences of a jurisdiction being on the blacklist remain largely unclear, clients may wish to review whether they...more

Trump Administration: 2017 Recap and 2018 Outlook

On January 20, 2017, businessman Donald J. Trump was sworn in as the 45th President of the United States following a contentious and unconventional 2016 presidential election. Republicans also successfully maintained control...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

International Tax Reform Is Here

by Alston & Bird on

The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act...more

Update on IRS Offshore Initiatives

by Moskowitz LLP on

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are...more

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

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

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

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

by Foodman CPAs & Advisors on

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...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

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

Tax Reform and Investment Management: Certain International Provisions

by K&L Gates LLP on

In addition to the very significant changes to the domestic provisions of the Internal Revenue Code (the “Code”), the Tax Cut and Jobs Act (the “Act”) made very significant changes to the taxation of foreign income of U.S....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

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

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