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Controlled Foreign Corporations

Blank Rome LLP

New Jersey Tax Court Rules That Individuals Are Not Subject to Tax on “Deemed Dividends” under IRC Section 965

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The New Jersey Tax Court has held that individual taxpayers were not required to include in their New Jersey gross income the undistributed earnings of controlled foreign corporations (“CFCs”) for purposes of the Gross Income...more

Katten Muchin Rosenman LLP

2024 Year-End Estate Planning: International Developments

It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024. US tax authorities are not shaking up the international private client landscape, but instead are providing...more

Latham & Watkins LLP

Final US Outbound Investment Rules to Be Effective January 2, 2025: Key Questions Answered

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The Final Rule prohibits or requires notification of certain US investments in Chinese and Chinese-controlled entities involved in semiconductors, quantum information technologies, and artificial intelligence....more

Blank Rome LLP

Departments Don’t Always Know Best

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Departments of Revenue are notorious for treating their guidance as the final and absolute word on an issue. However, that doesn’t mean that they are always right. The recent decision of the Oregon Tax Court in Microsoft...more

Goodwin

BIOSECURE Act Timeline

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The BIOSECURE Act passed the House of Representatives on September 9, 2024, with a bipartisan vote of 306–81. It has now moved to the Senate, which has its own version of the BIOSECURE Act already in play. If passed by the...more

Freeman Law

Tax Court Addresses a Difference in Dates in the TCJA

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In Varian Medical Systems, Inc. v. Commissioner, the Tax Court addressed a seeming oversight in the Tax Cuts and Jobs Act of 2017 (the “TCJA”) involving the effective dates for amendments to section 78 and the enactment of...more

Walkers

15% Global Minimum Tax Rate: Draft Legislation lodged in Jersey

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Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

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The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Freeman Law

Supreme Court Upholds Section 965 Mandatory Repatriation Tax

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On June 20, 2024, the U.S. Supreme Court issued its long-anticipated decision in Moore v. United States, in which a 7-2 majority upheld the constitutionality of the mandatory repatriation tax (“MRT”) under section 965 of the...more

Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

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The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Gray Reed

SCOTUS Upholds MFT: Moore Et Ux v. US

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On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the...more

BakerHostetler

The Protecting Americans’ Data from Foreign Adversaries Act - What Digital Advertisers, Publishers and Ad Platforms Need To Know

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The Protecting Americans’ Data from Foreign Adversaries Act (PADFA or the Act) was signed into law by President Joe Biden on April 24 as part of a larger foreign aid appropriations bill. Although other portions of the...more

Dorsey & Whitney LLP

The Supreme Court Update - June 20, 2024

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The Supreme Court of the United States issued four decisions today: Moore v. United States, No. 22-800: This case concerns the constitutionality of the Mandatory Repatriation Tax (“MRT”) included in the 2017 Tax Cuts and...more

BakerHostetler

Supreme Court Upholds Mandatory Repatriation Tax but Suggests Wealth Taxes a Step Too Far

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The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more

Freeman Law

El IRS actualiza reglas sobre los ajustes a la base gravable en las distribuciones a mitad de año por las CFC para evitar las...

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Durante años, había existido incertidumbre entre los profesionistas que se dedican a la materia fiscal sobre sobre si las ganancias obtenidas a mitad de año por una Corporación Extranjera Controlada (por sus siglas en inglés,...more

Miller Canfield

US Issues Final Regulations on FEOC Exclusions from Clean Vehicle Credit

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On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Proskauer - Tax Talks

Summary of the Biden Administration’s Fiscal Year 2025 Green Book Tax Proposals

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On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more

Blank Rome LLP

Microsoft Prevails in California Dispute on Inclusion of Gross Foreign Dividends in Apportionment Formula

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In a decision that may have significant repercussions regarding apportionment for California corporate tax purposes, the California Office of Tax Appeals (“OTA”) has denied the Franchise Tax Board’s (“FTB”) petition for a...more

Miller Canfield

Can Legislative History Restore a Repealed IRC Provision?

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Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

Goodwin

Corporate Transparency Act - Key Points

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Who must report? All US entities created by a filing made with a secretary of state, and all foreign entities registered to do business by the filing of a document with a secretary of state....more

Skadden, Arps, Slate, Meagher & Flom LLP

France Strengthens Foreign Investment Controls, Expands Jurisdiction to ‘Commercial Establishments’ Registered in France |...

On 28 December 2023, the French government adopted decree number 2023-1293 (Decree), together with an administrative order of the same date (Order), that expanded the scope of covered investments and covered activities under...more

Eversheds Sutherland (US) LLP

IRS Notice previews proposed regulations addressing PTEP basis of acquired CFCs

On December 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2024-16 (Notice) announcing their intent to issue proposed regulations relating to the determination of...more

Eversheds Sutherland (US) LLP

Moore questions: Impressions from oral argument

On December 5, 2023, the US Supreme Court heard oral arguments in Moore v. United States, addressing the constitutionality of the section 965 transition tax, which was enacted in the Tax Cuts and Jobs Act of 2017. Section 965...more

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