News & Analysis as of

Controlled Foreign Corporations

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

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

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

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

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

¿Sabía usted que la "Ley" tiene una Deducción por Dividendos Recibidos (DRD)?

by Foodman CPAs & Advisors on

La "Ley de Reducción de impuestos y empleos" (la "Ley") tiene el propósito declarado de que los EE.UU. se convierta a un sistema de impuestos “territorial". Antes de que se aprobara la Ley, la mayoría de las empresas de los...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

Did you know that the “Act” has a Deduction for Dividends Received (DRD)?

by Foodman CPAs & Advisors on

The “Tax Cuts and Jobs Act” (the “Act”) has a stated purpose of converting the U.S. to a “territorial” tax system. Before the Act was approved, most U.S. companies were incentivized to keep their earnings offshore. In the...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

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

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

by Foodman CPAs & Advisors on

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...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

US Tax Reform—Changes Impacting High Net Worth Individuals

by White & Case LLP on

On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was signed into law, accomplishing the most far-reaching US tax reform in decades. While the Act contains significant changes that will impact all US taxpayers, this...more

International Tax Reform: Adoption Of Territorial System And GILTI Tax

by Cole Schotz on

The recently enacted 2017 tax act (originally called the Tax Cuts and Jobs Act – “Tax Reform Act”) contains sweeping changes to US international tax rules that will affect international businesses and cross border...more

U.S. Taxation Of Foreign Income After Tax Reform

by Farrell Fritz, P.C. on

We’ve all heard about the profits that publicly-held U.S. corporations have generated overseas, and how those profits have, until now, escaped U.S. income taxation by virtue of not having been repatriated to the U.S. It...more

Insurance Topics We Will Be Watching in 2018

On its current course, this year could be both the best and the worst of times for insurance. The US economy continues to enjoy steady growth, stock indices continue to reach new highs and tax reform in the US allows both...more

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

New Tax Law (H.R. 1): Key Highlights Related to Interest Bearing Debt

by Proskauer - Tax Talks on

On Friday December 22, 2017, the President signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the US federal income tax laws in over three decades, and it will...more

International Tax Reform Is Here

by Alston & Bird on

The Tax Cuts and Jobs Act, signed into law on December 22, 2017, represents the biggest change to U.S. tax law since adoption of the 1986 Code. In addition to rate cuts and various individual and corporate reforms, the Act...more

Tax Act: Significant International Provisions

by WilmerHale on

Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more

Obscure Provision of New Tax Act Complicates Testamentary Tax Planning for Nonresidents with U.S. Beneficiaries

by Charles (Chuck) Rubin on

Nonresidents with a significant portfolio of U.S. stocks typically use a non-U.S. corporation to hold their portfolio. This is because U.S. stocks are generally subject to U.S. estate taxes at the death of their owner, and...more

Tax Reform and Investment Management: Certain International Provisions

by K&L Gates LLP on

In addition to the very significant changes to the domestic provisions of the Internal Revenue Code (the “Code”), the Tax Cut and Jobs Act (the “Act”) made very significant changes to the taxation of foreign income of U.S....more

Changes Abound in New Tax Bill for Multinational Companies

by Williams Mullen on

Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more

How Will Federal Tax Reform Impact Your Business in 2018 and Beyond?

On December 22, 2017, the U.S. enacted the largest overhaul of the federal tax code in more than three decades. This legislation introduces sweeping changes to the U.S. taxation of individuals and businesses....more

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