News & Analysis as of

CFC

UK Tax Round Up - November 2017

by Proskauer Rose LLP on

UK Tax News and Developments - The OTS publishes its report "Value added tax: routes to simplification" - On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

by Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

Tax Reform Bill May Eliminate Need to Limit Credit Support Attributable to CFCs for US Corporate Borrowers

by White & Case LLP on

Under current law, the direct or indirect pledge of the assets of a "controlled foreign corporation" (a "CFC") as collateral security for, among other things, a borrowing of a US person is treated as an investment in US...more

Controlled Foreign Corporation: Neither A Lender, Guarantor, Nor Pledgor Be?

by Farrell Fritz, P.C. on

Last week, we considered the U.S. taxation of a closely held foreign corporation that owned a minority interest in a partnership that was engaged in business in the U.S. This week, we turn our sights to the U.S. taxation of a...more

Federal Tax Guidance Regarding RICs’ Investments in Commodities, Certain PFICs, and “Securities”

by K&L Gates LLP on

The Treasury Department (Treasury) and the Internal Revenue Service (Service) recently issued proposed regulations that, if finalized as proposed, could have a significantly adverse effect on the ability of a regulated...more

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

by Morgan Lewis on

The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more

Treasury Department Issues Temporary and Proposed Regulations to Curb Inversions and Earnings Stripping

by White & Case LLP on

On April 4, 2016, the Internal Revenue Service and the Treasury Department issued temporary and proposed regulations formalizing rules contained in Notices 2014-52 and 2015-79 limiting corporate tax inversions, as well as...more

20-Year Zoltek Litigation Continues: Federal Circuit Reverses CFC Invalidity Ruling on Written Description, Obviousness Grounds - ...

by McDermott Will & Emery on

Addressing written description and obviousness issues, the US Court of Appeals for the Federal Circuit reversed the US Court of Federal Claims (CFC), holding that the CFC erred in finding the claims invalid under 35 USC § 112...more

European Commission Proposes Anti Tax Avoidance Directive - The proposed Council Directive is a further step towards tackling tax...

by King & Spalding on

Background - The Commission has published a proposal for a Council Directive, the ‘Anti Tax Avoidance Directive’ (the “Proposed Directive”), confirming the Commission’s intention to combat tax avoidance and to coordinate...more

EU Anti-Tax Avoidance Directive Published: Implications For United Kingdom Corporate Taxpayers

by Allen & Overy LLP on

On 28 January 2016 the EC published a proposal for a so-called Anti-Tax Avoidance Directive. If implemented it would apply to all taxpayers who are subject to corporate tax in an EU Member State, including corporate taxpayers...more

Tax Planning for Chinese Investment in U.S. Real Estate

by Bilzin Sumberg on

According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors...more

"Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson"

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border...more

New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

by Goulston & Storrs PC on

Earlier this week the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations...more

Use of Estonia in U.S. International Tax Planning

by Bilzin Sumberg on

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

Wrap-Up of Federal and State Chemical Regulatory Developments, July 2015

by Bergeson & Campbell, P.C. on

EPA Seeks Comment On Series 810 Test Guidelines: On June 17, 2015, the U.S. Environmental Protection Agency (EPA) announced the availability for comment of several Series 810, non-binding, draft test guidelines developed by...more

Home and Community-Based Services: Seven Things You Need to Know

by Baker Donelson on

Few people have a strong understanding of home and community-based services (HCBS), how they work, how they came about and why they are important. There are a number of reasons why HCBS experts are few and far between. Put...more

Global Tax News - January 2015

by DLA Piper on

A SWIFT LOOK AT OECD’S DISCUSSION DRAFTS ON BEPS PLUS ONE CHART SETTING OUT TIMELINES - During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to...more

IRS private letter ruling on non-conventional real estate assets enables taxpayer to convert to REIT: key points

by DLA Piper on

The Internal Revenue Service recently released a private letter ruling regarding the treatment of certain assets as qualifying “real estate” for real estate investment trust (REIT) purposes. That ruling effectively enabled...more

Tax Alert: New Chief Counsel Memorandum Revisits Definition of “Obligation” under IRC Section 956

by Fenwick & West LLP on

ILM 201436047 - In a recent memorandum, ILM 201436047 (Sept. 8, 2014), the IRS chief counsel seemingly exceeded the scope of its own regulations in advising that the amount of a CFC’s section 956 investment included...more

EPA Labeling Requirements for Products Containing or Manufactured with a HCFC Begin January 2015

by Beveridge & Diamond PC on

Effective January 1, 2015, products imported or manufactured after that date that contain or were manufactured with a hydrochlorofluorocarbon (HCFC) must be labeled before they may be placed into interstate commerce. These...more

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

by Bilzin Sumberg on

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

by Mintz Levin on

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

Tax Planning for the Privatization of the Space Industry

by Bilzin Sumberg on

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

Federal Circuit’s Metcalf Decision a Big Win for Contractors

In a recent decision, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) the supervising court for the Court of Federal Claims and the Boards of Contract Appeals, among others) clarified important legal principles...more

Information Letter: Update on legislative developments in Russia. Governmental De-offshoring initiatives. Proposed new CFC and...

by DLA Piper on

When it was first revealed by President Vladimir Putin a few years ago that the offshore-backed modus operandi for the Russian economy could no longer be tolerated, very few could have predicted that the Government would be...more

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