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White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

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In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

Burns & Levinson LLP

Client Advisory: Repatriation Tax on Shareholders | Moore v. U.S.

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The Tax Cuts and Jobs Act of 2017 amended the law to introduce a new, one-time, mandatory repatriation tax on trillions of dollars of accumulations held abroad by American-controlled foreign entities. The tax is imposed on...more

A&O Shearman

Notice 2024-16 Announces Limited Guidance Under Section 961(c)

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On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more

Eversheds Sutherland (US) LLP

Another CAMT crumble: IRS releases Notice 2024-10 addressing potential double counting from CFC dividends

On December 15, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Notice 2024-10 (Notice) addressing the potential double counting of income from controlled foreign corporations...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint

Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Gearing Up for Pillar Two

Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more

Cadwalader, Wickersham & Taft LLP

Pin-pointing Residence

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Hogan Lovells

Dividend income is excluded from the EBITDA for the purpose of the Spanish interest limitation rule

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The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more

Brownstein Hyatt Farber Schreck

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Freeman Law

Reviewing a Foreign Legal Structure

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Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more

Freeman Law

Navigating the Branch Profits Tax

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The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more

Orrick, Herrington & Sutcliffe LLP

The UK Qualifying Asset Holding Company Regime - Highlights

The United Kingdom ("UK") Qualifying Asset Holding Company ("QAHC") regime (at Schedule 2 to Finance Act 2022) comes into force on 1 April 2022. The HM Revenue & Customs ("HMRC") policy paper dated 27 October 2021 states:...more

Freeman Law

Purging the PFIC Taint

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A passive foreign investment company (PFIC) is a foreign corporation that meets either of two tests: an Asset test or an Income test. A U.S. person who is a direct or indirect shareholder of a corporation that satisfies...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

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On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

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In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

McDermott Will & Emery

[Webinar] Novità Fiscali Fine 2020 - January 21st, 3:00 pm - 5:00 pm CET

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Proseguendo una consuetudine dello Studio, che ha sempre raccolto l’interesse e l’approvazione da parte Vostra, abbiamo organizzato, quest’anno in formato webinar, un incontro sulle principali novità fiscali recentemente...more

McDermott Will & Emery

[Webinar] Tax News At The End Of 2020 - January 21st, 3:00 pm - 5:00 pm CET

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Continuing a practice of the Firm, which has always garnered your interest and approval, we have organized, this year in webinar format, a meeting on the main tax innovations recently introduced and of interest to businesses....more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

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

Holland & Knight LLP

Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses

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The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

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

Proskauer - Tax Talks

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

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On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - June 2019

In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more

Foodman CPAs & Advisors

Understanding How to Compute a U.S. shareholder’s GILTI inclusion

The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more

Proskauer Rose LLP

UK Tax Round Up - December 2018

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UK Developments - Taxpayer succeeds in judicial review case against HMRC - On 22 November 2018, the Upper Tribunal published its decision on the judicial review case of R. (on the application of Vacation Rentals (UK)...more

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