News & Analysis as of

Tax Securities

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

IRS Issues Guidance Related to the Filing Obligations Resulting from the New CFC Downward Attribution Rules

by Benesch on

As discussed in our previous Client Bulletin U.S. Tax Reform: Key Considerations for Non-U.S. Families with Connections to the United States, the Tax Cuts and Jobs Act (the “Act”) changed the stock attribution rules that are...more

New Tax Law Changes Deductibility of Government Settlement Payments in False Claims Act, SEC, FINRA, and Other Types of Cases

by Foley & Lardner LLP on

The new tax law changed the deductibility of settlements with government agencies in some circumstances thereby increasing the cost to companies to settle these cases. The deduction arose from the section in the Internal...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

Private equity investments

by Ropes & Gray LLP on

Neill Jakobe, Ropes & Gray private equity partner and managing partner of the firm’s Chicago office, discusses some of the key trends impacting private equity investments. --------- Some of the key trends we're seeing in...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

Disposal of shares by non-residents: Gaining the capital perspective

by Hogan Lovells on

Capital gains tax (CGT) was introduced to the Income Tax Act (the Act) on 1 October 2001. The basis from which it operates is that if a capital asset is sold at a profit, the profit is subject to CGT, and if it is sold at a...more

Tax Cut Could Spur Further Shareholder Activism

by Morrison & Foerster LLP on

The Tax Cuts and Jobs Act (the “Act”) was intended principally to simplify the tax code, reduce individual and corporate tax rates, and allow for the repatriation of cash held overseas at a discounted tax rate. But, as with...more

Getting In on Bitcoin: Canadian Income Tax Implications of Cryptocurrencies

by Bennett Jones LLP on

Are you contemplating the acquisition of a cryptocurrency such as Bitcoin or Litecoin? The reasons for, and circumstances surrounding, such acquisitions vary widely, including "crypto-mining" activities, buying and selling...more

Estate planning for your business: Use an ESOP to properly address your closely held company

If a substantial portion of one’s net worth is tied up in his or her closely held business, it’s critical to have an exit strategy. This article explains why an employee stock ownership plan is one tool that offers a...more

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...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

Tax Act Could Impact Tax-Exempt Bonds

by Bowditch & Dewey on

One of the key components of the recently passed Tax Cuts and Jobs Act is the reduction in the corporate tax rate from 35 percent to 21 percent for tax years beginning after December 31, 2017. Banks, financial institutions,...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

FDIC Letter on the Accounting and Reporting Implications of the New Tax Law

by Weiner Brodsky Kider PC on

The FDIC recently issued a Financial Institution Letter (“Letter”) to provide guidance on certain accounting and reporting implications of the new tax law, which was enacted on December, 22, 2017. The Letter highlights...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

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

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

Preparation for 2017 Fiscal Year-End SEC Filings and 2018 Annual Shareholder Meetings

by Mintz Levin on

As our clients and friends know, each year Mintz Levin provides an analysis of the regulatory developments that impact public companies as they prepare for their fiscal year-end filings with the Securities and Exchange...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The Fed held its last Open Markets Committee meeting under outgoing Chair Yellen, and it agreed to hold the benchmark rate in a range between 1.25% and 1.5%. Here’s the lowdown....more

Disclosure Implications of the Tax Cuts and Jobs Act

by Dorsey & Whitney LLP on

As companies prepare their Form 10-K and proxy statement disclosures, they will be challenged with disclosing the impact of the Tax Cuts and Jobs Act on performance results for the purposes of financial reporting as well as...more

Tax Reform Impacts Use of Transaction-Related Deductions

by Bryan Cave on

Recent tax legislation passed by Congress (the “Act”) generally eliminated a corporation’s ability to carry back net operating losses (“NOLs”) to prior years1 and instead allows the NOLs to be carried forward...more

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

by McDermott Will & Emery on

The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The...more

Big Incentives Available for Opportunity Zone Investments

by Miller Canfield on

Investors got some great news in the Tax Cuts and Jobs Act, which enables them to delay paying the tax on capital gains. If a taxpayer generates a capital gain and invests that amount in a qualified opportunity fund within...more

UK Tax Round Up - January 2018

by Proskauer Rose LLP on

The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

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