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Corporate Taxes Base Erosion Tax Tax Reform

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

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

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International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Kramer Levin Naftalis & Frankel LLP

Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more

Cadwalader, Wickersham & Taft LLP

EU’s Proposal on Implementing Pillar Two

The European Commission has published its proposal for a Directive to implement the OECD Pillar Two Global Anti-Base Erosion rules (the “OECD GloBE Model Rules”)....more

Holland & Knight LLP

Biden Administration's Made in America Tax Plan: Interaction with OECD Inclusive Framework

Holland & Knight LLP on

The American Jobs Plan is a proposal to increase investment in infrastructure, the production of clean energy, the care economy and other priorities. The Made in America Tax Plan (Tax Plan) is the vehicle to pay for the...more

BakerHostetler

BEPS 2.0 - International Tax Reform Primer for SALT Experts

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It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

This deeper dive into the White House’s proposed tariffs on $200 billion worth of Chinese goods helps us understand just exactly how buying for the average American could change....more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Mayer Brown

Infocast’s 2018 Solar Power Finance & Investment Summit Soundbites

Mayer Brown on

Below are soundbites from panelists at Infocast’s Solar Power Finance & Investment Summit from March 19th to 22nd in Carlsbad, CA. It was an extremely well-attended event and the mood of the participants was generally...more

Carlton Fields

Tax Reform: Insurance Company Provisions

Carlton Fields on

Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry....more

Troutman Pepper

How Will Recent Tax Legislation Affect the Renewable Energy Sector?

Troutman Pepper on

The Bipartisan Budget Act of 2018 (Pub. L. No. 115-123) (the Budget Act) was signed into law on February 9. The legislation took effect roughly seven weeks after President Trump signed into law an Act to Provide for...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

McGuireWoods LLP

It’s a Fixer-Upper

McGuireWoods LLP on

A technical corrections bill is still all talks at this point. Congressional tax writers are unlikely to drop a bill until the Joint Committee on Taxation (JCT) issues its bluebook. Even if a package of corrections is...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Insurance Companies

On December 22, 2017, President Donald Trump signed into law a budget reconciliation act commonly referred to as the Tax Cuts and Jobs Act (TCJA). This sweeping tax bill represents the most comprehensive reform of U.S. tax...more

Bracewell LLP

Bracewell Tax Report: February 2018

Bracewell LLP on

The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...more

Proskauer - Tax Talks

Impact of Recent Tax Legislation on M&A Transactions

Proskauer - Tax Talks on

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...more

Sheppard Mullin Richter & Hampton LLP

Real Estate Aspects of Tax Reform

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), the most extensive overhaul of the United States tax regime in over thirty years. The new tax laws will have a significant impact upon...more

BakerHostetler

2017 Federal Tax Reform Legislation as Finally Enacted Preserves New Markets Tax Credits and Also Historic Tax Credits, With Some...

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On Dec. 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (the “Act”), enacting broad reforms to the Internal Revenue Code. In previous BakerHostetler Alerts published Nov. 8 and Nov. 10, we outlined...more

Mintz - Energy & Sustainability Viewpoints

Energy & Sustainability 2017 Year in Review: Tax Bill (Part 1 of 4)

In this four-part series, we revisit 2017’s biggest developments in Energy & Sustainability-related news, milestones, policy changes, and financial transactions. This is the first installment of the series. The biggest...more

Mayer Brown

What Is the Impact of Tax Reform on US Wind Tax Equity Deals?

Mayer Brown on

A Word About Wind has published our article What Is the Impact of Tax Reform on US Wind Tax Equity Deals? in its blog (subscription required) and newsletter. ...more

Goulston & Storrs PC

Tax Reform Advisory: Provisions Impacting Debt Financing

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. Most...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

McDermott Will & Emery

US Tax Reform Measures Affecting Foreign Multinationals

McDermott Will & Emery on

On December 22, 2017, President Trump signed broad tax reform legislation into law that, among other things, reduced the corporate income tax rate to 21 percent and reformed the US international tax system. This article...more

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