News & Analysis as of

Foreign Entities Income Taxes

Strafford

[Webinar] Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Income and Expenses, FTCs - March...

Strafford on

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more

McDermott Will & Emery

Be Careful What You Wish For: Minnesota May Be on the Precipice of Enacting Worldwide Combined Reporting at the Worst Possible...

It has been widely reported that the Minnesota Legislature has advanced an omnibus tax bill that would require the inclusion of the “entire worldwide income” of combined corporate income tax filers engaging in a unitary...more

Bilzin Sumberg

Navigating Pandora’s Hallelujah Mountains: Civil Law Foundations, U.S. Tax Classification and Related Penalty Issues

Bilzin Sumberg on

One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more

McDermott Will & Emery

[Event] West Coast Tax Forum: California & Beyond: The Impact Of State, Federal And International Tax Developments On Golden State...

McDermott Will & Emery on

Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges. Join members...more

White & Case LLP

Mexico 2020 Tax Reforms

White & Case LLP on

The Mexican Congress approved with some adjustments the Tax Bill presented by the President on September 8, 2019, that included a proposal of Decree through which various provisions of the Income Tax Law, the Value Added Tax...more

International Lawyers Network

Establishing A Business Entity In Puerto Rico

Puerto Rico offers many advantages to individuals and companies that decide to establish business operations on the Island. These include unique local tax incentives; a strong, dedicated, and skilled bilingual labor force;...more

Fox Rothschild LLP

LB&I Announces Five More Compliance Campaigns, Bringing Total To 50 Campaigns

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The Internal Revenue Service’s Large Business and International division (LB&I) announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first 13 campaigns,...more

Hogan Lovells

Intangible services acquired from affiliated entities - limitation in the treatment of expenses incurred as revenue generating...

Hogan Lovells on

On 1 January 2018, the amendments to the CIT Act entered into force. As pointed out in the explanatory memorandum to the bill, the principal objective of the introduced changes is the closer monitoring of the Corporate Income...more

Stinson LLP

Minnesota Corporate Franchise Tax Change for Foreign Disregarded Entities

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The Minnesota Department of Revenue issued its position on foreign disregarded entities of corporate taxpayers on October 4, 2017. In response to the Minnesota Supreme Court decision filed August 2, 2017 in Ashland Inc. v....more

Lowndes

IRS Re-Releases Partnership Audit Regulations

Lowndes on

The IRS has released proposed regulations implementing the new centralized partnership audit rules. These regulations are virtually identical to the regulations that were released and then pulled in January of this year. ...more

Locke Lord LLP

UK Supreme Court Decision in Anson v. HMRC Reverses Established Tax Treatment of US LLCs

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In its July 1, 2015 decision in the case of Anson v. HM Revenue & Customs (2015 UKSC 44), the Supreme Court of England and Wales ruled that a Delaware limited liability company was “transparent” for UK income tax purposes. A...more

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