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Corporate Taxes

Blake, Cassels & Graydon LLP

Rétablir l’avantage de l’Alberta : simplicité accrue pour les entreprises

Le gouvernement de l’Alberta cherche à attirer les investissements nationaux et internationaux en rendant la province plus concurrentielle sur le plan de la création et de l’exploitation d’entreprises. Pour ce faire,...more

Dentons

Tax & Privacy Alert: European Commission proposal would create additional reporting obligations for digital platforms (DAC 7)

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On July 15, 2020, the European Commission (“EC”) published a proposal for a Council directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation (“DAC 7”). The proposal changes the existing...more

Patterson Belknap Webb & Tyler LLP

District Court Addresses “Straddle Year” Treatment for Federal Income Tax in Bankruptcy

In an appeal of a bankruptcy court’s decision, a district court judge recently addressed the treatment of the “straddle year” for federal income tax under the Bankruptcy Code, which “does not appear to have been decided by...more

McDermott Will & Emery

Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

Dechert LLP

More details emerge of the UK’s Job Retention Bonus Scheme

Dechert LLP on

Following the Chancellor’s announcement on 8 July 2020 that employers of furloughed employees would be entitled to a job retention bonus if they kept employees employed until the end of January 2021, the Government published...more

Latham & Watkins LLP

Treasury Department, IRS Issue Final GILTI High-Tax Exception Regulations

Latham & Watkins LLP on

The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes. Key Points: ..Taxpayers can elect on an annual basis whether to...more

Blake, Cassels & Graydon LLP

Restoring the Alberta Advantage: Increased Simplicity for Businesses

The Government of Alberta is looking to attract national and foreign investments by making the province a more competitive jurisdiction to form and operate a business in. To aid these efforts, Alberta has amended numerous...more

Morgan Lewis

HM Revenue & Customs to Get Preferential Status as of 1 December 2020 (UPDATED)

Morgan Lewis on

With effect from 1 December 2020, the UK’s HM Revenue & Customs will be given preferential creditor status for certain taxes which a company has collected but failed to pay to HMRC on the date it enters insolvency. ...more

Farrell Fritz, P.C.

Tax Considerations for LLC Operating Agreements

Farrell Fritz, P.C. on

July 30, 2020 The operating agreement is the governing document with respect to the management and conduct of a limited liability company (an “LLC”). It outlines the financial and functional decisions of the business and,...more

Farrell Fritz, P.C.

Virus To Economic Shutdown To Bankruptcy? Not Necessarily, But Be Prepared

Farrell Fritz, P.C. on

Bankruptcy Resurgent? The economic shutdown, and the ensuing recession, triggered by the COVID-19 pandemic have jeopardized the survival of many businesses and, in some cases, of entire industries. Notwithstanding the...more

Murtha Cullina

Massachusetts Department of Revenue Issues Guidance in Response to CARES Act Tax Relief Provisions

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On July 13, 2020, the Massachusetts Department of Revenue issued Technical Information Release 20-9 to explain the impact of selected tax provisions of the CARES Act on Massachusetts taxation. Highlights of this guidance...more

Seyfarth Shaw LLP

Net Operating Losses of Tax-Exempt Organizations with More Than One Unrelated Trade or Business

Seyfarth Shaw LLP on

Since the enactment of the unrelated business income tax in 1950, section 512(b)(6)[1] and its predecessor allowed organizations subject to the unrelated business income tax (UBIT) to use the net operating loss (NOL)...more

Dentons

Uganda Governance Advisory – Submit your Voluntary Disclosure

Dentons on

The Uganda Revenue Authority has issued an invitation to the taxpaying public to submit a voluntary disclosure and benefit from a remission of interest and fines on previously undeclared and unpaid tax or late tax payments....more

Troutman Pepper

NOL Carryback Issues for Companies That Departed a Consolidated Group, Including Split Waivers and AMT Credit Refunds

Troutman Pepper on

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act, H.R. 748) included changes to the federal income tax loss (NOL) carryforward provisions under Section 172 of the Internal Revenue Code. One of the significant...more

Thompson Coburn LLP

Proposed tax plans of the 2020 presidential candidates

Thompson Coburn LLP on

With the presidential election in November a little more than three months away, the presumptive nominees, former Vice President Joe Biden and President Donald Trump, are set to square off on a variety of policy issues. As it...more

Holland & Knight LLP

The GILTI High-Tax Exception: Is it a Viable Planning Option?

Holland & Knight LLP on

The Global Intangible Low-Taxed Income (GILTI) provisions were enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA). Under the GILTI provisions, a U.S. shareholder essentially is taxed on the active earnings of a...more

Dentons

The Italian Constitutional Court gives certainty to the tax treatment of share deals (in Italian)

Dentons on

With sentence no. 158/2020 (filed on 21 July 2020), the Constitutional Court declared the legitimacy issues raised by the Cassation in reference to the current wording of article 20 (on the "Interpretation of the acts") of...more

Jones Day

EU Court Overturns Commission Decision in Landmark Apple Tax Case

Jones Day on

The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question gave rise to a selective advantage under EU...more

White & Case LLP

EU General Court strikes a blow to Commission approach to fiscal State aids in the Apple tax case

White & Case LLP on

The General Court has upheld a challenge to a 2016 Commission decision that had required Ireland to recover €13.2 billion in illegal State aid from Apple, on account of alleged preferential tax treatment for the...more

Holland & Knight LLP

Se reglamentan normas sobre el impuesto de normalización tributaria en Colombia

Holland & Knight LLP on

El 14 de julio de 2020, el Ministerio de Hacienda expidió el Decreto 1010 de 2020, por el cual se reglamentan aspectos relacionados con el impuesto de normalización tributaria y saneamiento de activos en Colombia....more

Dentons

Costa Rica: Term is extended until July 20 for the submission of the Value-Added Tax return corresponding to activities carried...

Dentons on

On Monday, July 13, 2020, the Ministry of Finance issued an official statement, in which it informs that the term is extended until July 20 for taxpayers to file without penalties the declarations of Value-Added Tax (VAT)...more

Alston & Bird

Talk About a Summer Beach Read – Final FDII and GILTI Regulations Released

Alston & Bird on

The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you....more

Pierce Atwood LLP

COVID-19: Maine Income Tax Does Not Conform to FFCRA and the CARES Act

Pierce Atwood LLP on

Maine Revenue Services (MRS) has informed taxpayers that Maine does not conform to the federal tax changes enacted in the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security...more

Foster Garvey PC

Curiosity Killed the Cat – Unfortunately the Oregon Legislature’s Curiosity Has Not Gone That Far With Respect to Our CAT: The...

Foster Garvey PC on

During the special session, the Oregon legislature passed House Bill 4202 (“HB 4202”), which Governor Kate Brown signed into law on June 30, 2020. The legislation, which makes several technical and policy changes to the...more

Dorsey & Whitney LLP

Covid-19 Tax Relief Makes Winners out of Losses (for some)

Dorsey & Whitney LLP on

The CARES Act, signed into law on March 27, 2020 in the wake of the onset of the Covid-19 pandemic, contained numerous changes to U.S. federal income tax law. One such change applied to the deductibility of net operating...more

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Updated: May 25, 2018:

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Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

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Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

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Updates to This Policy

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