News & Analysis as of September 26, 2024

Controlled Foreign Corporations

+ Follow

Can Legislative History Restore a Repealed IRC Provision?

Miller Canfield on 2/16/2024

Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

The Death of the Deemed Dividend

Burns & Levinson LLP on 11/14/2018

The “deemed dividend” rule, the source of much wrangling between multi-national borrowers and lenders over the years, may be on its way out....more

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Latham & Watkins LLP on 8/15/2018

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Japan Legal Update - Volume 34 | March 2018

Jones Day on 3/30/2018

Corporate Governance - Subcommittee Prepares Interim Proposal for Amendment to the Companies Act - On February 14, 2018, the Companies Act (in relation to Corporate Governance, etc.) Sub-Committee of the Legislative...more

Amid the Economic Uncertainties of the Brexit, New Challenges in Corporate Tax Structuring for UK Companies (And Their Parents,...

Nutter McClennen & Fish LLP on 6/27/2016

The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more

5 Results

View per page