Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
The California Office of Tax Appeals (OTA) denied a request for rehearing of a July 2023 OTA opinion favorable to Microsoft Corp. that could have wide-ranging impacts for a water's edge filer in California, particularly one...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more
Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more
1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more
While there are a few different forms of “corporate” entities in Israel, this guide will focus on companies and partnerships as these are the entities that the non-Israeli businessman is most likely to set up or invest in if...more
The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more
On March 31, 2022, the Luxembourg Administrative Court of Appeal ruled that, in order to determine the minimum acquisition value of a participation for the purposes of the Luxembourg parent-subsidiary exemption, the...more
A. Types of Business Entities - 1. Description of The Types of Entities - Pursuant to Turkish Foreign Direct Investment Law, foreign investors are free to make foreign direct investments in Turkey and shall be subject...more
Withdrawing Value- Any tax adviser who has represented closely held businesses and their owners long enough realizes there are certain recurring themes that transcend the otherwise unique characteristics of the industry of...more
Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more
Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 9, 2020 – November 13, 2020... November 9, 2020: The IRS released Notice 2020-75...more
The New Jersey Division of Taxation issued a notice on November 5th solving the “trapped dividend exclusion” issue faced by many taxpayers as they prepared to file their first New Jersey combined Corporate Business Tax (CBT)...more
The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more
Nebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not...more
Choice of Entity- The owners of a closely held business are generally free to select the form of business entity through which they will operate their business. In most cases, hopefully, the decision to operate as a sole...more
Eighteen months after the passage of the Tax Cuts and Jobs Act (TCJA or the Act), tax practitioners and taxpayers alike still are looking to Treasury for guidance to interpret and fill in gaps in the new tax laws. The hasty...more
Key Points- Controlled foreign corporations may now provide credit support for U.S. corporate parents without adverse U.S. income tax consequences. Market practice will likely shift toward more controlled foreign...more
On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 of the Internal Revenue...more
Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more
On December 20, 2018, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed “anti-hybrid” regulations (the “Proposed Regulations”) under sections 267A, 245A(e), and...more