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Corporate Taxes › Foreign Corporations › Cross-Border Transactions

Dorsey & Whitney LLP

Share Buyback Transactions: U.S. Tax Consequences may differ for each U.S. Shareholder

Dorsey & Whitney LLP on

On Thursday, November 4, 2021, the Office of the Superintendent of Financial Institutions announced that, subject to approval by the superintendent, Canadian banks and other financial institutions may begin repurchasing their...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Skadden, Arps, Slate, Meagher & Flom LLP on

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Alston & Bird

Proposed Regulations Nix Foreign Goodwill Exception to Tax on Outbound Transfers

Alston & Bird on

The IRS and Treasury recently issued proposed regulations under Section 367 with bad news for taxpayers. Citing aggressive taxpayer positions, the proposed rules do away with the foreign goodwill exception and restrict the...more

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