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International Trade Tax

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

New Reporting Requirements For Foreign-Owned Disregarded Entities Have Taken Effect

by Akerman LLP on

The final regulations enacted in late 2016 that impose new reporting requirements on foreign-owned disregarded entities have now taken effect, bringing changes that will add significant complexity for many taxpayers this tax...more

What Do You Think About…Deemed Repatriation?

by K&L Gates LLP on

The tax reform bill signed into law by President Trump on December 22, 2017, taxes U.S. shareholders on their share of the previously untaxed deferred income of foreign corporations. Known as “deemed repatriation,” this tax...more

Impact of US Tax Reform on Insurance Companies

On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more

Presidential Proclamation Imposes Safeguard Tariff on Solar Panel Components

by King & Spalding on

On January 23, 2018, President Donald Trump issued a presidential proclamation imposing a safeguard tariff on solar panel components. The U.S. Trade Representative (“USTR”) released the following terms of the tariff...more

Window on Washington - Vol. 2, Issue 7

by Clark Hill PLC on

Outlook for This Week in the Nation's Capital - FY18 Appropriations Wrap-up. House Appropriators are trying to finish drafting the FY18 Omnibus Appropriations bill by March 14 in order to give Congress enough time to pass...more

Bracewell Tax Report: Week of February 12

by Bracewell LLP on

The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more

Connecticut Responds to the Federal Repatriation Tax

by McDermott Will & Emery on

Earlier this month, Connecticut Governor Dan Malloy released his Governor’s Bill addressing the various state tax implications of the federal tax reform bill enacted by Congress in December 2017, commonly referred to as the...more

Inexplicably, Section 956 Survives Tax Reform Intact

by Alston & Bird on

How did a section of the Internal Revenue Code destined for repeal by both the House and Senate versions of the Tax Cuts and Jobs Act survive the final Act? Our International Tax Group examines the future application of...more

New Regulations on Withholding Income Tax for Overseas Investors in China

by McDermott Will & Emery on

To promote the growth of foreign investment, the “Notice on Policies concerning Temporarily Not Levying Withholding Tax on Distributed Profit used for Direct Investment by Overseas Investors” was jointly issued on December...more

US “TCJ Act” Tightening of CFC Rules Eliminates Common Approach To Post-Death Avoidance Of US Beneficiary Taxation

by Bryan Cave on

On December 22, 2017, President Trump signed into law H.R. 1 (Pub. L. No. 115-97), known as the Tax Cuts and Jobs Act (the “Act”). The Act is the first major overhaul of the Internal Revenue Code (the “Code”) in more than 30...more

Summary of New Tax Bill

This letter provides a summary of the material provisions of the new tax bill. In order to make this extraordinarily complex bill somewhat understandable, I have left off a number of details and simplified the discussion, so...more

Corp Fin Director Discusses Policy, Outreach and Future Areas of Focus

by WilmerHale on

Earlier this month, SEC Division of Corporation Finance Director William Hinman delivered the keynote address at the Practising Law Institute’s Seventeenth Annual Institute on Securities Regulation in Europe. Director Hinman...more

U.S. Tax Reform: Key Considerations for Non-U.S. Families with Connections to the United States

by Benesch on

The Tax Cuts and Jobs Act (the Act) was signed into law on December 22, 2017. The Act is without a doubt the most impactful reform to the Internal Revenue Code since the tax reform of 1986. While it does not appear that the...more

French Finance Act for 2018 and Amending Finance Acts for 2017: Key Tax Measures for Businesses and Individuals

by K&L Gates LLP on

The first and second French Amending Finance Acts for 2017 and Finance Act for 2018 were enacted on December 2, December 29 and December 31, 2017, respectively (the “Acts”). The Acts introduce a progressive reduction of the...more

Impact of Recent Tax Legislation on M&A Transactions

by Proskauer - Tax Talks on

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more

Additional Rum Cover Over for Puerto Rico and the US Virgin Islands Approved in 2018 Budget Legislation

by McDermott Will & Emery on

On February 9, 2018, both houses of Congress approved the “Bipartisan Budget Act of 2018,” complex legislation that includes important modifications to an arcane law known as the “rum cover over,” which is an important...more

Tax Considerations for Foreign-Owned U.S. Corporations After 2017 Tax Act

Following the enactment of the 2017 Tax Act, foreign-owned U.S. corporations are, in general, subject to a federal corporate income tax rate of 21% of their world-wide taxable income, as well as to state income taxes that...more

Orrick's Financial Industry Week In Review

CFTC Files Eight Anti-Spoofing Enforcement Actions against Three Banks (Deutsche Bank, HSBC & UBS) & Six Individuals - On January 29, 2018, the Commodity Futures Trading Commission ("CFTC"), along with the Department of...more

Federal Tax Reform and Minnesota Tax Policy: A Preliminary Guide to Conformity

by Faegre Baker Daniels on

Since the enactment of the Tax Cuts and Jobs Act (TCJA), Minnesota’s Department of Revenue (DOR) has been analyzing what the TCJA will mean for Minnesota. The TCJA marks the most significant changes to the Internal Revenue...more

Expansion of Subpart F under the Tax Reform Act

by McDermott Will & Emery on

Under Subpart F, certain types of income and investments of earnings of a foreign corporation controlled by US shareholders (controlled foreign corporation, or CFC) are deemed distributed to the US shareholders and subject to...more

Significant Tariffs on Imported Solar Cells and Modules Until 2022

by Bryan Cave on

President Trump has imposed a tariff-rate quota (TRQ) on imported solar cells and a tariff on imported solar modules, both effective February 7, 2018. Imports into the U.S. of Crystalline Silicon (c-Si) Photovoltaic (CSPV)...more

Tax Reform and Investment Management: Effect on Registered Investment Companies

by K&L Gates LLP on

The Tax Cuts and Jobs Act (“Act”) significantly changed U.S. tax federal law. Although the Act does not amend any of the provisions directly affecting the qualification or other taxation of a “regulated investment company”...more

CBSA Announces 2018 Trade Verification Priorities

by Bennett Jones LLP on

In a New Year's tradition, the Canada Border Services Agency (CBSA) has published its trade verification (audit) priorities for 2018. The audits cover three programs that affect the amount of duties and Goods and Services...more

EU Court: (former) French and German tax anti-abuse rules not in line with EU law

by Dentons on

The Court of Justice of the European Union (CJEU) issued two important judgments regarding abuse presumptions in relation to dividend distributions by French and German companies to parent companies resident in other EU...more

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

by Foodman CPAs & Advisors on

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

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