News & Analysis as of

Controlled Foreign Corporations

Managing Separate GILTI Calculations

by McDermott Will & Emery on

The 2017 tax act expanded Subpart F to require an inclusion in income of “global intangible low-taxed income” (GILTI) of a controlled foreign corporation (CFC). This is generally the amount of a CFC’s income in excess of its...more

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

Sanctions Update: Rewind Your Iran Compliance Policy to January 2016

by Perkins Coie on

The United States will reimpose sanctions against Iran to implement President Donald Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), a multilateral agreement under which Iran agreed to curb...more

The European Commission Investigates U.K. Tax Rules

by Shearman & Sterling LLP on

On October 26, 2017, the European Commission (EC) announced a formal State aid investigation into a U.K. exemption from U.K. anti-tax avoidance rules for certain transactions by multinational groups, the so-called Group...more

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

by Alston & Bird on

On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded...more

Expect Focus - International - March 2018

by Carlton Fields on

Trends Against BITS and Investor State Dispute Resolution - In my first Expect Focus International article (http://bit.ly/2G9Demu), I suggested that investors doing business outside the United States should do so in...more

IRS releases Notice 2018-26 - retroactively disregarding certain accounting method changes and entity classification elections

The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more

New York State Responds to Federal Tax Reform

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

French Anti-Corruption Agency Publishes Information Expected from Companies During Agency Inspections

by Jones Day on

The Situation: The French Anti-Corruption Agency has published the questions and documentation that companies will be expected to answer and provide when inspected by the Agency. The Result: The French Anti-Corruption...more

Transition tax - enough about how it works; here is what doesn’t work

The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-16 (the Notice) providing additional guidance regarding the transition tax in section 965 of the Internal Revenue Code of...more

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

by Carlton Fields on

The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Decoding the Tax Cuts and Jobs Act – Part IX: Impact on M&A Transactions

by Garvey Schubert Barer on

The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”). Virtually none of...more

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

by Dechert LLP on

President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

The End of the Offshore Voluntary Disclosure Program is Near!!! What Can I do?

by Sanford Millar on

On March 13, 2018 the IRS announced that the formal Offshore Voluntary Disclosure Program (“OVDP” would end September 28, 2018....more

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

by Foodman CPAs & Advisors on

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

IRS Releases Notice Addressing the "Transition Tax" Under Section 965 of the Code

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

by Latham & Watkins LLP on

Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more

Foreign-Derived Intangible Income

by Alston & Bird on

It’s probably the next-best part of the Tax Cuts and Jobs Act for multinationals. Our Federal Tax Group investigates the foreign-derived intangible income regime and how you can use it....more

Japan Legal Update - Volume 34 | March 2018

by Jones Day on

Corporate Governance - Subcommittee Prepares Interim Proposal for Amendment to the Companies Act - On February 14, 2018, the Companies Act (in relation to Corporate Governance, etc.) Sub-Committee of the Legislative...more

Tax Reform Act Changes to CFC Attribution Rules

The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more

Understanding the “GILTI” of the Tax Reform

by Foodman CPAs & Advisors on

The Tax Cuts and Jobs Act (TCJA) introduced several complex, hard to understand international tax provisions to the Internal Revenue Code. One of them is the tax on Global Intangible Low-Taxed Income (GILTI). Beginning with...more

New Tax Law May Result in Additional Taxes for Certain US Persons who Directly or Indirectly Own Equity in a Foreign Corporation

by White & Case LLP on

The new federal tax rules (informally known as the Tax Cuts and Jobs Act ("TCJA")), signed into law on December 22, 2017, significantly expand the situations in which a foreign corporation will be treated as a "controlled...more

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

by Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

Shareholders of S Corps can defer payment of Transition Tax

by Foodman CPAs & Advisors on

The Tax Cuts and Jobs Act (TCJA) includes 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

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

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