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GILTI tax Net Operating Losses

McDermott Will & Emery

As Minnesota Moves Toward GILTI Taxation, New Jersey May Be Moving Away from It

McDermott Will & Emery on

We previously reported that the Minnesota Legislature was considering imposing mandatory worldwide combined reporting through an omnibus tax bill. Subsequent to our report and in the face of numerous criticisms, Minnesota...more

Gould + Ratner LLP

Pending Changes to Illinois Tax Laws Include SALT Workaround

Gould + Ratner LLP on

Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more

Pierce Atwood LLP

Maine Governor’s Proposed Supplemental Budget – Federal (Non)Conformity Summarized

Pierce Atwood LLP on

Maine Governor Janet Mills submitted a supplemental budget, as amended by a change package submitted on January 25, 2021. The supplemental budget is notable for its retroactive conformity to the Internal Revenue Code (IRC) as...more

McDermott Will & Emery

CARES Act Could Result in Taxation of More GILTI in New Jersey

The federal stimulus bill (the CARES Act), HR 748, which was signed into law by President Trump on March 27, includes certain corporate income tax provisions designed to provide relief to corporate taxpayers. One such...more

Skadden, Arps, Slate, Meagher & Flom LLP

CARES Act Tax Considerations

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more

Fenwick & West LLP

Proposed Section 382 Regulations Raise International Tax Issues for Post-Acquisition Restructuring

Fenwick & West LLP on

The new regulations proposed in September under Section 382(h) regarding built-in-gain raise several international tax issues that companies planning for post-acquisition integration of loss corporations should be aware of....more

Pierce Atwood LLP

Maine Legislature Passes Tax Conformity Legislation - Now Awaits Governor’s Signature

Pierce Atwood LLP on

In a special session, the Maine legislature passed tax conformity legislation on August 30, 2018, after having failed to pass this legislation prior to its spring adjournment. The legislation is now on the Governor’s desk...more

Eversheds Sutherland (US) LLP

Employee benefit arrangements potentially affected by revised UBIT calculations

In Notice 2018-67, released on August 21, 2018, the Internal Revenue Service (IRS) sought comments and provided interim guidance on changes in the calculation of unrelated business income tax (UBIT) enacted in the Tax Cuts...more

Alston & Bird

Section 338 and the Tax Act

Alston & Bird on

The 2017 tax act substantially changed the considerations and results for various uses of Section 338 elections, or not making Section 338 elections, or selling assets when the buyer, seller, or target is foreign. This has...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

BCLP

Impacts of Tax Reform on a Company's Financial Statement

BCLP on

Recent tax legislation, generally referred to as the Tax Cuts and Jobs Act (the “Act”), will have a significant impact on financial statement reporting. The Act was signed into law on December 22, 2017, and the financial...more

Proskauer - Tax Talks

Impact of Recent Tax Legislation on M&A Transactions

Proskauer - Tax Talks on

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions. Some of these rules are very complex, particularly in...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

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