News & Analysis as of

Financing Corporate Taxes

Pillsbury Winthrop Shaw Pittman LLP

Establishing and Managing a Business in the UK 2022

Overseas investors are welcome in the UK. Save as set out below, there are no specific laws prohibiting foreign investment in the UK nor are there any business requirements for UK participation in the ownership or management...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Commercial Activity Tax – Ohio Board of Tax Appeals relies on federal income tax treatment of vehicle financing transactions...

A common question in many Ohio commercial activity tax (CAT) audits is whether federal tax treatment may be relied upon. Although the statute says it should (R.C. 5751.01(K)), the Tax Commissioner is often reluctant to accept...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more

Holland & Knight LLP

Se amplía la fecha máxima de facturación electrónica para los contribuyentes del régimen SIMPLE

Holland & Knight LLP on

Con motivo de las modificaciones realizadas por la Ley de Financiamiento – Ley 1943 de 2018 – Colombia actualmente se encuentra en proceso de implementar el sistema de facturación electrónica con validación previa a su...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Capital Markets Expected to Remain Robust in 2018

The U.S. high-yield and investment-grade debt markets saw significant increases in 2017 over 2016 in dollar volume and number of issuances. The U.S. equity indices reached new highs throughout the year, with the Standard &...more

Orrick, Herrington & Sutcliffe LLP

Tax Cuts And Jobs Act - Impact On Financing Transactions

The Tax Cuts and Jobs Act (the "Tax Act") was signed into law by President Trump on December 22, 2017. With respect to financing transactions, the relevant changes include the following:...more

Skadden, Arps, Slate, Meagher & Flom LLP

European Commission Opens State Aid Investigation Into Finance Company Exemption From UK CFC Rules

On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more

Carlton Fields

Taking Your Business International

Carlton Fields on

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...more

Mintz

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

Mintz on

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

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