Corporate Taxes, IRS, Repatriation

IRS Extends Date for Section 965 Liability Transfer Agreement

Orrick, Herrington & Sutcliffe LLP on 10/16/2018

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

LB&I adds new campaigns on virtual currency and transition tax

Eversheds Sutherland (US) LLP on 7/11/2018

On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more

Draft North Carolina Tax Legislation Released

Smith Anderson on 4/18/2018

On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on 12/21/2017

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

Five Things to Know about the Tax Cuts and Jobs Act

Pillsbury Winthrop Shaw Pittman LLP on 12/8/2017

Even with the bill still in Conference, here are some things businesses should follow closely. Both House and Senate Bills call for deemed repatriation of accumulated foreign profits at reduced tax rates. ...more

“Return of Basis” Repatriation Strategy Tested in Tax Court

Bilzin Sumberg on 9/25/2014

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated...more

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Bilzin Sumberg on 6/6/2014

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

Corporate Taxes › Internal Revenue Service › Repatriation