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Corporate Taxes Repatriation

Allen Barron, Inc.

How Did Moore v. United States Change U.S. Tax Law?

Allen Barron, Inc. on

We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and...more

Freeman Law

Supreme Court Upholds Section 965 Mandatory Repatriation Tax

Freeman Law on

On June 20, 2024, the U.S. Supreme Court issued its long-anticipated decision in Moore v. United States, in which a 7-2 majority upheld the constitutionality of the mandatory repatriation tax (“MRT”) under section 965 of the...more

Gray Reed

SCOTUS Upholds MFT: Moore Et Ux v. US

Gray Reed on

On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the...more

Dorsey & Whitney LLP

The Supreme Court Update - June 20, 2024

Dorsey & Whitney LLP on

The Supreme Court of the United States issued four decisions today: Moore v. United States, No. 22-800: This case concerns the constitutionality of the Mandatory Repatriation Tax (“MRT”) included in the 2017 Tax Cuts and...more

BakerHostetler

Supreme Court Upholds Mandatory Repatriation Tax but Suggests Wealth Taxes a Step Too Far

BakerHostetler on

The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more

International Lawyers Network

Establishing A Business Entity In India (Updated)

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

Freeman Law

Ninth Circuit Rejects Constitutional Challenges to Section 965 Tax

Freeman Law on

In Moore v. United States, the U.S. Ninth Circuit Court of Appeals recently rejected arguments that the mandatory repatriation tax imposed under section 965 of the Internal Revenue Code violated the Constitution’s...more

Holland & Knight LLP

Se reglamentan normas sobre el impuesto de normalización tributaria en Colombia

Holland & Knight LLP on

El 14 de julio de 2020, el Ministerio de Hacienda expidió el Decreto 1010 de 2020, por el cual se reglamentan aspectos relacionados con el impuesto de normalización tributaria y saneamiento de activos en Colombia....more

Pillsbury - SeeSalt Blog

Nebraska Clarifies Treatment of IRC 965 Repatriation Income

Nebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not...more

Orrick, Herrington & Sutcliffe LLP

IRS Extends Date for Section 965 Liability Transfer Agreement

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

Eversheds Sutherland (US) LLP

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

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

Smith Anderson

Amended North Carolina Tax Bill Advances

Smith Anderson on

Previous Alerts dated April 17 and May 15 described the North Carolina draft tax legislation developed by the Revenue Laws Study Committee for introduction in the General Assembly’s short session, which began on Wednesday....more

Ballard Spahr LLP

Pennsylvania Publishes Guidance Regarding New Repatriation Tax

Ballard Spahr LLP on

The Pennsylvania Department of Revenue (the Department) published an Information Notice setting forth its position as to how the repatriation income and deduction under Section 965 of the Internal Revenue Code (the Code) (the...more

Smith Anderson

Draft North Carolina Tax Legislation Released

Smith Anderson on

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

Dechert LLP

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

Dechert LLP on

President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

Foley & Lardner LLP

The Effect of Tax Reform on Financing Transactions: Thoroughly Review Your Company's Situation

Foley & Lardner LLP on

In general, the effects of the new tax law should be very favorable to most corporate borrowers. Nevertheless, there may be situations where a corporate borrower benefits economically from a lower tax rate and other favorable...more

Eversheds Sutherland (US) LLP

How will Georgia conform to federal tax reform? Annual legislation introduced

The Georgia Legislature has introduced its annual Internal Revenue Code (IRC) conformity bill—HB 821. Georgia conformity is typically updated annually to apply for the most recent tax year. In light of the recently enacted...more

Foodman CPAs & Advisors

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

Foodman CPAs & Advisors

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

WilmerHale

Tax Act: Significant International Provisions

WilmerHale on

Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more

Stoel Rives LLP

Deemed Repatriation of Foreign Deferred Income May Decrease State Taxable Income

Stoel Rives LLP on

A revenue raising provision in the recently enacted federal tax reform legislation, the Tax Cuts and Jobs Act (the Act), may have an unintended consequence of decreasing a taxpayer’s state taxable income because of the way...more

Latham & Watkins LLP

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

Latham & Watkins LLP on

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

Williams Mullen

Changes Abound in New Tax Bill for Multinational Companies

Williams Mullen on

Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more

Parker Poe Adams & Bernstein LLP

How Will Federal Tax Reform Impact Your Business in 2018 and Beyond?

On December 22, 2017, the U.S. enacted the largest overhaul of the federal tax code in more than three decades. This legislation introduces sweeping changes to the U.S. taxation of individuals and businesses....more

Orrick, Herrington & Sutcliffe LLP

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

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