News & Analysis as of

CFCs

Goldberg Segalla

The Devil You Know… is not TFA (yet)

Goldberg Segalla on

Through the modern industrial age, there’s always been a push-and-pull between the utility of our innovations and the risks they often inadvertently create. In the 70’s, we discovered the synthetic pesticide that was so...more

ArentFox Schiff

The US Supreme Court to Rule on the TCJA Transition Tax: Is the Realization Requirement Soon to Be No Moore?

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On June 26, the US Supreme Court agreed to hear the appeal of Moore v. United States, a development that reverberated throughout the world of tax. The Moore case deals with the constitutionality of the transition tax under...more

Mintz - Health Care Viewpoints

CMS Issues Updated Guidance for Home Dialysis Provided at Nursing Homes

On March 22, 2023, the Centers for Medicare & Medicaid Services (CMS) issued updated guidance for home dialysis services performed in a skilled nursing facility or nursing home (the Updated Guidance). CMS first issued...more

Foley Hoag LLP - Environmental Law

News Flash! International Cooperation on the Environment Remains Possible

In these times of much woe, it’s always noteworthy when the mainstream media reports good news. Especially when it’s good news about effective international cooperation on environmental protection issues....more

Pillsbury Winthrop Shaw Pittman LLP

Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions

The new law generally imposes a 15% alternative minimum tax on book income of corporations with book income in excess of $1 billion. Public companies will generally be subject to a 1% excise tax on stock buybacks. ...more

Cadwalader, Wickersham & Taft LLP

House Passes Build Back Better Act

Here's a summary of the tax provisions in the Build Back Better Act, as passed by the House. I. Introduction - On November 19, 2021, the House of Representatives passed the Build Back Better Act (the BBBA)....more

McDermott Will & Emery

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

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As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

McDermott Will & Emery

Weekly IRS Roundup September 21 – September 25, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020... September 21, 2020: The IRS released Announcement...more

McDermott Will & Emery

New Proposed Regulations Would Revise the Application of Section 163(j) to CFCs

McDermott Will & Emery on

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

Fenwick & West LLP

New Considerations in Taxation of Foreign Exchange Transactions After the 2017 Act

Fenwick & West LLP on

Foreign exchange gain or loss is a feature of most cross-border business activity and has tax implications under two different sets of rules governing foreign currency transactions (§ 988) and foreign currency translation (§§...more

Kramer Levin Naftalis & Frankel LLP

The Service Grants Relief to US Shareholders of “Foreign-Controlled” CFCs

On Oct. 1, the Internal Revenue Service (the Service) issued Revenue Procedure 2019-40 (the Revenue Procedure), which offers guidance relating to ownership by certain U.S. persons of stock in “controlled foreign corporations”...more

White & Case LLP

Mexico 2020 Tax Reforms

White & Case LLP on

The Mexican Congress approved with some adjustments the Tax Bill presented by the President on September 8, 2019, that included a proposal of Decree through which various provisions of the Income Tax Law, the Value Added Tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Cross-Border Estate Planning

The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more

Goulston & Storrs PC

Tax Reform Advisory: Provisions Impacting Debt Financing

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On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. Most...more

Goulston & Storrs PC

Tax Reform Advisory: Corporate and General Business Provisions

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

Goulston & Storrs PC

Tax Reform Advisory: International Provisions

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

Alston & Bird

The PFIC Regulations Get a Facelift

Alston & Bird on

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 9, No. 3

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IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

Goodwin

Financial Services Weekly News - September 2016 #3

Goodwin on

Editor's Note - Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more

Polsinelli

Treasury Notice on Inversions Leaves Basic Inversion Transactions Intact

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In This Issue: - Deferred Earnings and Profits of CFCs - Code Section 956(e) - Code Section 7701(l) - Code Section 304(b)(5)(B) - Code Section 7874 - Request for Comments -...more

Morrison & Foerster LLP

State + Local Tax Insights -- Spring 2014

In This Issue: - Where’s Walden? Finding Protection under the Due Process Clause - Upcoming Speaking Engagements - CFCs and Subpart F Income in a California Water’s-Edge Election and What’s Wrong with the Apple...more

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