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Freeman Law

International Tax Concepts: Dual-Status Taxpayers

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A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...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

Proskauer Rose LLP

UK Tax Round Up - May 2022

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Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Hogan Lovells

Obligaciones para Organizaciones de la Sociedad Civil 2022

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Durante el 2022 debemos contemplar ciertas obligaciones en este año así como nuevas disposiciones de interés para las OSC en diversas materias. Es importante que las revises para que cumplas con todos los requisitos que pide...more

Miller Nash LLP

Today in Tax: Eligibility of Electronic Services Income for FDII Deduction

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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more

Brownstein Hyatt Farber Schreck

Taxation & Representation, December 14, 2021

Senate Finance Committee Democrats Update Build Back Better. On Saturday afternoon, Senate Finance Committee Chair Ron Wyden (D-OR) released legislative text for the committee’s portion of the Build Back Better Act. The text...more

Orrick, Herrington & Sutcliffe LLP

Super deduzione per i costi di R&S e credito d’imposta – le novità del Decreto Fiscale

È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more

Orrick, Herrington & Sutcliffe LLP

Super Deduction for R&D Costs and Tax Credit - What's New in the Tax Decree

The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, October 26, 2021

Negotiations Update. After months of negotiation, Democrats appear close to an agreement between the White House, progressives and influential moderate Sens. Joe Manchin (D-WV) and Kyrsten Sinema (D-AZ) on budget...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, October 5, 2021

TAX TIDBIT - Where In the Tax World Are Manchin and Sinema? The contents and scope of the Build Back Better Act—the budget reconciliation measure through which congressional Democrats are attempting to enact most of...more

Freeman Law

The Tax Court in Brief - September 2021 #2

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Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...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

Skadden, Arps, Slate, Meagher & Flom LLP

Biden Administration’s Green Book Proposes Significant Changes to Tax Regime

On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Freeman Law

The Tax Court in Brief - November 2020

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Proskauer Rose LLP

UK Tax Round Up - May 2020

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UK COVID-19 developments - Proposed deferral of DAC6 and DAC2 - The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Bracewell LLP

Bracewell Tax Report - September 2018

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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

Bracewell LLP

Proposed Regulations on Immediate Expensing Provide Greater Clarity for the Energy Industry

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On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more

Bracewell LLP

Bracewell Tax Report - August 2018

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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

Alston & Bird

Trickle Down Guidance: Interim Notices Tackle Key International Reforms

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On April 2, in quick succession, the IRS and Treasury announced notices addressing two provisions added by the Tax Cuts and Jobs Act (TCJA): the repatriation tax under Section 965 and withholding on non-publicly traded...more

Carlton Fields

Tax Reform: Insurance Company Provisions

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

Carlton Fields

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

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The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IX: Impact on M&A Transactions

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The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”). Virtually none of...more

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