News & Analysis as of

Corporate Taxes

U.S. Tax Reform Effort Moves Forward

by Hogan Lovells on

On September 27, 2017, Republican leaders of the tax reform effort in the U.S. House of Representatives, the U.S. Senate, and the Trump Administration released a "Unified Framework for Fixing Our Broken Tax Code," providing...more

Thou Shalt Not Hold Real Property In A Corporation

by Farrell Fritz, P.C. on

“When will they ever learn?”- No, I am not channeling Seeger. I am referring to those individuals[i] who continue to acquire real property (“RP”) in, or who contribute RP to, corporations. In just the last couple of...more

2017 Federal Business Income Tax Legislation

by Dickinson Wright on

Republicans are still expected to come up with significant changes in income taxation. The latest proposed significant change is to reduce the maximum marginal federal tax rate on corporations to 20% from its current...more

Trump Tax Reform Roadmap Released

by Butler Snow LLP on

On Wednesday President Trump and congressional Republicans unveiled their long-awaited framework for overhauling the United States tax code. Although much of the content was expected, the proposal is notable because it...more

Tracking Tax Reform: Fall 2017 Update

by Locke Lord LLP on

On September 27 the “Big Six,” which includes Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, and other top Republicans in the House and Senate, released the “Unified Framework for Fixing Our...more

An Overview of the Unified Republican Framework on Tax Reform

On September 27, 2017, President Trump and the Republicans unveiled the elements of their tax reform framework. Here’s a quick overview of some of the proposed changes...more

Some Quick Thoughts on the “Big Six” Unified Framework

by Proskauer - Tax Talks on

Yesterday, the Trump Administration, the House Committee on Ways and Means, and the Senate Finance Committee proposed a “unified framework” for tax reform. The members of the working group are House Speaker Paul Ryan (R-WI),...more

The proposed US tax reform: repatriation alternatives for multinationals operating in Latin America

by DLA Piper on

The proposed US tax reform may incentivize multinational companies that have made investments in Latin America to pursue repatriation alternatives such as dividend distributions and capital reduction. However, the...more

Big 6 framework: main points of the tax reform effort

by DLA Piper on

As anticipated, the Joint Statement on Tax Reform – the document released by the Big 6 tax negotiators, Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, Senators Mitch McConnell and Finance...more

Trump Administration and Congressional Leaders Release Tax Reform Framework

by Shearman & Sterling LLP on

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

Republicans release new tax reform framework

by Dentons on

On September 27, 2017, the Trump administration and Republican leaders in Congress released their "Unified Framework for Fixing our Broken Tax Code." This nine-page document is the result of months of meetings on tax reform...more

Tax Reform Update: Administration and Congressional Officials Unveil Framework

by Latham & Watkins LLP on

The proposal would significantly change US taxation of businesses, setting the stage for legislative negotiations, but omits some key details. On September 27, a group of Trump Administration and Congressional leaders...more

President Releases Tax Reform Framework

by Ropes & Gray LLP on

On September 27, 2017, the White House and a group of congressional leaders, commonly referred to as the “Big Six”, released a joint framework for proposed tax reform. The framework sets out five goals: middle-class tax...more

Republicans Announce Tax Reform Framework

After months of speculation, President Trump and the Republicans have finally announced their framework for tax reform. While specific details are not known, the key elements of the framework include: - Reducing the...more

Big Six Releases Tax Framework: It’s Time to Get Dynamic

Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, House Speaker Paul Ryan, Senate Majority Leader Mitch McConnell, House Ways and Means Committee Chairman Kevin Brady and Senate Finance...more

The Path to Tax Reform 2017: September Framework Sets Stage for Passage Before Year-End

by BakerHostetler on

With the release today of a Republican budget framework (the Framework) reflecting the shared view of the White House and House and Senate leaders – and with GOP majorities in both chambers of Congress – there is a likelihood...more

2018 Dutch Tax Plan - changes to Dutch dividend withholding tax

by DLA Piper on

The Dutch Ministry of Finance has published the 2018 Budget and, in connection with it, the 2018 Tax Plan. The 2018 Tax Plan contains a number of already anticipated changes to Dutch tax legislation effective as of January 1,...more

IRS Expands Scope of Spin-Off Private Letter Rulings in 18-Month Pilot Program

by Shearman & Sterling LLP on

On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more

Taxpayer Challenges Department Authority to Adjust NOL Carryforward, When NOL Was Generated in Tax Years Otherwise Closed by...

by Reed Smith on

Can a Department of Revenue auditor reduce a taxpayer’s deduction for a net operating loss (“NOL”) carryforward, even if the NOL was generated in a tax year that is closed under the statute of limitations? This question is...more

IRS Resumes Issuing Transactional Spin-Off Rulings

by Proskauer - Tax Talks on

On September 21, 2017, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2017-52 (the “Rev. Proc.”), introducing an 18-month “pilot program” in respect of corporate “spin-off,” “split-up” and “split-off”...more

Debt vs. Equity: Form & Substance Matter

by Farrell Fritz, P.C. on

Some lessons need to be repeated until learned. It’s a basic rule of life. Don’t tug on Superman’s cape; don’t spit into the wind; don’t pull the mask off that old Lone Ranger; and if you are going to make a loan, give it the...more

Is a Business Tax Reform Game Plan Beginning to Take Shape?

by McDermott Will & Emery on

Substantial tax reform is underway and the business community is intently awaiting details of this activity with the aim of positioning themselves to maximize opportunities and minimize any costs or risks that reform may...more

UK Tax Round Up - September 2017

by Proskauer Rose LLP on

UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

New California Tax Agencies’ Roles Clarified

On September 16, 2017, California Governor Jerry Brown signed Assembly Bill (A.B.) 131 into law, making various changes to the Taxpayer Transparency and Fairness Act of 2017 (Act) enacted on June 27, 2017. The Act overhauled...more

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