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Corporate Taxes Repatriation Income Taxes

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

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

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

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

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

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

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

Sheppard Mullin Richter & Hampton LLP

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

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

Jones Day

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

Jones Day on

The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

Proskauer - Tax Talks

Trump Administration Announces Outline of Its Tax Proposal

Proskauer - Tax Talks on

Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more

Baker Donelson

President Trump Has Been Inaugurated. What's Next for Tax Reform?

Baker Donelson on

President Donald J. Trump has just been inaugurated as the 45th President of the United States and his proposals regarding tax reform played a key role throughout his entire presidential campaign. Because Republicans retained...more

Kramer Levin Naftalis & Frankel LLP

Tax Reform in the New Administration

The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...more

Butler Snow LLP

Is Tax Reform On the Horizon?

Butler Snow LLP on

2017 will bring Republican control to D.C. It will also potentially bring tax reform. Both President Elect Donald Trump and House Republicans have proposed sweeping changes to the U.S. tax system, which we have briefly...more

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