News & Analysis as of

Corporate Taxes Base Erosion Tax Alternative Minimum Tax

Eversheds Sutherland (US) LLP

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Eversheds Sutherland (US) LLP

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

Orrick, Herrington & Sutcliffe LLP

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

Locke Lord LLP

New Tax Law May Reduce Tax Benefit for Cross-Border Affiliated Insurance/Reinsurance Premiums

Locke Lord LLP on

On December 22, 2017, the President signed into law H.R. 1, known generally as the Tax Cuts and Jobs Act (the “TCJA”), which makes widespread changes to the Internal Revenue Code. The TCJA includes a number of provisions that...more

Jones Day

The U.S. Tax Cuts and Jobs Act: Fundamental Changes to Business Taxation

Jones Day on

Signed into law December 22, 2017, the "Tax Cuts and Jobs Act" represents the most comprehensive reform to the U.S. federal tax code in a generation. The Act's most notable provisions include significant reductions in both...more

Kramer Levin Naftalis & Frankel LLP

Tax Reform

On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more

Goulston & Storrs PC

Tax Reform Advisory: Corporate and General Business Provisions

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

Orrick, Herrington & Sutcliffe LLP

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

Goulston & Storrs PC

Tax Reform Advisory: International Provisions

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

Hogan Lovells

Sweeping U.S. Tax Bill Signed Into Law

Hogan Lovells on

The provisions of the new tax law – almost all of which go into effect on January 1, 2018 – represent the most significant revisions to the U.S. tax code that have occurred in 30 years. The Act makes sweeping and major...more

Proskauer - Tax Talks

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference...

Proskauer - Tax Talks on

On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee...more

Proskauer - Tax Talks

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

Proskauer - Tax Talks on

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more

Hogan Lovells

U.S. Tax Reform in Final Stretch

Hogan Lovells on

This past week, on 1 December, the Senate voted 51-49 to advance its version of U.S. tax reform legislation. This sets the stage for a conference committee process to occur over the next two weeks, in which the Senate and...more

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