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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

FinCEN Clarifies Upcoming FBAR Due Date For Calendar Year 2017

by Fox Rothschild LLP on

Today the Treasury Department’s Financial Crimes Enforcement Network posted a “FBAR Due Date Clarification” on its website, which confirms that the annual filing deadline for FinCEN Form 114 (commonly referred to as the FBAR...more

Orrick's Financial Industry Week In Review

Interagency Statement on Accounting and Reporting Implications of the New Tax Law - On January 18, 2018, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal...more

Examining the cultural shift on tax avoidance

Against the backdrop of the Panama and Paradise Papers, legal tax avoidance has become a significant moral challenge for companies. Our latest Financial Crime Conversation looked at the cultural shift on tax....more

Funds Talk: February 2018

Global Regulators Increasingly Shifting Focus to Cryptocurrency - After years of allowing cryptocurrency transactions to fly under the radar, financial market regulators are beginning to turn their attention to virtual...more

U.S. Court Favors Aircraft Financier in Non-Citizen Trust Case

District court case shines a light on the extent and limits of a lender’s duties in both structuring loan transactions and exercising remedies. Borrowers need to be mindful in structuring the tax and cross-border aspects...more

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