News & Analysis as of

Corporate Taxes Tax Cuts and Jobs Act Multinationals

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

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In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and International Tax Changes

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A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

Holland & Knight LLP

Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses

Holland & Knight LLP on

The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - June 2019

In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more

Proskauer - Tax Talks

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption – Limits “Deemed Dividends” for U.S. Corporate...

Proskauer - Tax Talks on

Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders. ...more

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: US Tax Reform and Cross-Border M&A: Considering the Impact, One Year In

Many of the core provisions in the Tax Cuts and Jobs Act (TCJA) — including the corporate tax rate reduction and the fundamental reworking of the U.S. international tax regime — were geared toward addressing the uncompetitive...more

Rosenberg Martin Greenberg LLP

Year-End Tax Planning: More Important This Year Than Ever

It’s the holiday season! The last few weeks were spent in winter festivities, getting together with friends and family, and rushing around to the sound of holiday music. Major Tax Changes Stem from the Tax Cut and Jobs Act...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

BakerHostetler

IRS Issues Regulations That May Affect Borrowing Costs and Financing Terms of US Multinationals

BakerHostetler on

Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more

BCLP

Proposed Regulations Impact Treatment of CFC Pledges and Guarantees

BCLP on

On October 31, 2018, the Treasury Department released proposed regulations (the “Proposed Regulations”) that reduce certain amounts otherwise includible in the taxable income of a corporate U.S. shareholder of a controlled...more

Burns & Levinson LLP

The Death of the Deemed Dividend

Burns & Levinson LLP on

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

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Eversheds Sutherland (US) LLP

Ireland after US Tax Reform - What does it mean for business?

Ireland has an open, pro-business economy that offers significant opportunities to multinational companies, including as a gateway into the European market for US multinationals across all business sectors. Ireland remains...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...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

Latham & Watkins LLP

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

Latham & Watkins LLP on

Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Mergers and Acquisitions: New Opportunities and Pitfalls

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more

Skadden, Arps, Slate, Meagher & Flom LLP

An In-Depth Look at the Impact of US Tax Reform on Mergers and Acquisitions

On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...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

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

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