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Corporate Taxes

Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

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If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more

Mayer Brown

Quote-part de benefices perçue d une SCCV et taxe sur les salaires

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Le Conseil d’État juge que les quotes-parts de bénéfices perçues par une société dans des sociétés civiles doivent être traitées comme des produits financiers non soumis à la TVA, remettant en cause l’exonération de taxe sur...more

Mayer Brown

Cession à prix minoré et acte anormal de gestion

Mayer Brown on

La Cour administrative d’appel de Lyon confirme la requalification par l’administration fiscale d’une cession de titres à prix minoré par une société au fils de son dirigeant en acte anormal de gestion compte tenu des liens...more

Mayer Brown

Qualification de titres acquis lors d’une augmentation de capital suivie d’une cession

Mayer Brown on

La Cour administrative d’appel de Nancy confirme que la moins-value constatée lors de la cession de titres souscrits dans le cadre d’une recapitalisation préalable à la cession d’une filiale reste non déductible, ces titres...more

Fenwick & West LLP

Tax Court Says AbbVie's $1.6B Break Fee Payment to Shire Properly Deducted as Ordinary Expense

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A break fee in a merger-gone-south can be deducted as an ordinary expense, the U.S. Tax Court held today, finding for biopharmaceutical giant AbbVie and rejecting the IRS’s argument that AbbVie must treat the fee as a capital...more

Latham & Watkins LLP

Demystifying Spinoffs: Complex “IPOs” With a Sophisticated Tax Overlay

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In a spinoff, a public company separates one or more of its businesses into a new, publicly traded company. For the public company that initiates it, a spinoff can achieve a number of critical business and financial...more

Morrison & Foerster LLP

Re-domiciling Companies to Hong Kong

From May 23, 2025, companies may transfer their domicile to Hong Kong under a new regime which will allow them to preserve their legal identity and will not interrupt business operations. To qualify, companies must meet...more

DLA Piper

Danish Tax Agency Issues New Guidelines on VAT Refunds for Incorrectly Invoiced Output VAT

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On 21 May 2025, the Danish Tax Agency published new guidelines introducing revised administrative practice on the procedure for obtaining VAT refunds in cases involving incorrectly invoiced output VAT. Previously, a refund...more

Pillsbury - Propel

Founder Stock Vesting: What It Is and Why It Matters

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A key step in forming a company is issuing equity to the Founder(s). This equity is commonly referred to as “Founder’s Stock.” When issuing Founder’s Stock, it is important to consider whether a vesting schedule should...more

Proskauer - Tax Talks

One Big Beautiful Bill: Update on Provisions for Nonprofits

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On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Revised House Bill”). The Revised House Draft Bill contains certain changes to the original bill that was released...more

DLA Piper

New VAT Guidelines on Company Vehicles for Employees

DLA Piper on

The French tax authorities have issued new guidelines on the VAT treatment of company cars provided to employees. When a vehicle is provided for a defined consideration, it is considered a taxable service. This includes...more

DLA Piper

Italian Tax Authority Provides Guidance on VAT Treatment of Personnel Secondment Arrangements

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Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more

Seyfarth Shaw LLP

Hong Kong Launches Company Re-domiciliation Regime

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In a move to enhance Hong Kong’s status as a global business and financial hub, and to attract foreign companies to take advantage of Hong Kong’s taxation system and professional services–thereby encouraging investment and...more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

K&L Gates LLP on

Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

McGuireWoods Consulting

Corporate Tax Changes In Illinois FY 2026 Budget Package

The 2025 regular session of the Illinois General Assembly adjourned on June 1, 2025. The General Assembly passed a fiscal year (FY) 2026 budget package which includes corporate tax changes that will significantly impact...more

Proskauer Rose LLP

UK Tax Round Up - May 2025

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Welcome to the May edition of our UK Tax Round Up, which discusses two interesting judgments, one on the question of whether a distribution from a Jersey company was of a “capital nature” and the other on whether a loan to a...more

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Fox Rothschild LLP

Changes in Washington State Tax Law Will Impact Businesses

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Washington recently enacted major tax law changes that will affect many businesses operating in the state. Here’s what you need to know: Changes to the Definition of Incidental Investment Income - Washington law now...more

Pillsbury - Policyholder Pulse blog

The Beginning of the End of an Era? Competition to Delaware’s Supremacy as Corporate Domicile and Implications for D&O Insurance

Delaware has long been the leading jurisdiction in which companies incorporate. According to Delaware’s published statistics from 2023...more

Husch Blackwell LLP

Tax Credit Transfers May Have Unexpected State Tax Consequences

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One of the most celebrated features of the Inflation Reduction Act (“IRA”) is the ability to sell tax credits, including the Production Tax Credit (“PTC”) under Internal Revenue Code (“IRC”) § 45 and the Investment Tax Credit...more

Kilpatrick

4 Key Takeaways | A National State and Local Tax Update

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Kilpatrick’s David Hughes and Jordan Goodman gave a national SALT update at the high-profile AGN International “2025 Americas Regional Meeting” in Toronto on June 3....more

Lowenstein Sandler LLP

Section 280G Unpacked: Pitfalls and Planning for Tech Startups

In this episode of Just Compensation, Megan Monson and Jessica I. Kriegsfeld talk to Anthony O. Pergola, Vice Chair of Lowenstein’s Emerging Companies & Venture Capital practice group, about the complexities and challenges of...more

McDermott Will & Emery

IRS Roundup May 15 – June 2, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025....more

White & Case LLP

Important Tax Update: Luxembourg Court Decision on Interest Free Loans and Debt to Equity Ratio – A Global Impact

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International transactions, such as private equity deals, mergers and acquisitions, and financing arrangements, frequently leverage Luxembourg entities as holding companies or joint ventures. It is common for such companies...more

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