Corporate Taxes, Tax Code, Tax Planning

Recognising “Imported Losses” Under the UK’s Loan Relationship Rules

Cadwalader, Wickersham & Taft LLP on 8/30/2024

The United Kingdom (“UK”) has specific corporate tax rules on the taxation of loan relationships (parts 5 and 6 of the Corporation Tax Act 2009 (the “Loan Relationships Regime”)). The Loan Relationships Regime contains rules...more

Tax Residency Status Modification: Mexican Tax Implication

Freeman Law on 12/15/2022

For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on 8/24/2020

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Weekly IRS Roundup August 19 – 23, 2019

McDermott Will & Emery on 8/27/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019. August 20, 2019: The IRS released a proposed regulation that provides...more

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on 9/18/2018

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Comprehensive Tax Reform in Place as Congress Passes the Tax Cuts and Jobs Act

Nutter McClennen & Fish LLP on 12/27/2017

On December 20, 2017, Congress passed the most extensive package of reforms to the United States income tax system since the overhaul of the tax code in 1986. Enacting tax reform has been a key priority of the Trump...more

Tax Reform Update: A Call for Committee Action

Burr & Forman on 10/5/2017

On September 27, 2017, the Secretary of the Treasury, the Director of the National Economic Council, the Chair of the U.S. House Ways and Means Committee, the Chair of the U.S. Senate Finance Committee, the Speaker of the...more

Corporate Taxes › Tax Code › Tax Planning