News & Analysis as of

Controlled Foreign Corporations Tax Avoidance

Cadwalader, Wickersham & Taft LLP

EU’s Ambition Beyond BEPS 2.0

On May 18, 2021, the European Commission (the Commission) of the European Union (the EU) published a communication on “Business Taxation for the 21st Century” (the Communication), setting out a long-term vision to provide a...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Womble Bond Dickinson on

Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more

Alston & Bird

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

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

Hogan Lovells

Budget 2017

Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Alston & Bird

Treasury Issues Final Regulations Under Section 956

Alston & Bird on

On November 3, 2016, the Treasury issued final regulations (T.D. 9792) that set forth guidance on when a controlled foreign corporation (CFC) has a deemed repatriation under Section 956 in ...more

Proskauer - Tax Talks

EU Council Agrees on Final Anti Tax Avoidance Directive

Proskauer - Tax Talks on

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

A&O Shearman

Anti Tax Avoidance Directive

A&O Shearman on

On 21 June 2016, the EU Council reached agreement on the EU Anti Tax Avoidance Directive (“ATAD”). The ATAD is expected to be adopted in a forthcoming ECOFIN meeting, possibly on 12 July 2016. The Council had reached...more

Latham & Watkins LLP

European Commission Proposes an Anti-Tax Avoidance Directive

Latham & Watkins LLP on

The proposed Council Directive marks another, significant, though likely problematic, step towards tackling tax avoidance across Member States. Background - The European Commission (the Commission) has been moving...more

McDermott Will & Emery

Treasury and IRS Issue New Temporary Treasury Regulations

McDermott Will & Emery on

On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued new temporary Treasury regulations addressing the application of Internal Revenue Code Section 956 to certain...more

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