News & Analysis as of September 18, 2024

Income Taxes › Foreign Affiliates

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

The Tax Court in Brief - November 2020

Freeman Law on 11/24/2020

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

McDermott Will & Emery on 9/3/2020

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

Bracewell Tax Report: March 2018

Bracewell LLP on 4/6/2018

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on 12/21/2017

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Eversheds Sutherland (US) LLP on 4/26/2016

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

IRS Issues Notice Announcing Intention to Require Gain Recognition on Certain Transfers of Property to Partnerships with Related...

Morrison & Foerster LLP on 8/25/2015

I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more

"Treasury Releases Notice Addressing Transactions Involving Related-Party Partnerships"

Skadden, Arps, Slate, Meagher & Flom LLP on 8/18/2015

On August 6, 2015, the Department of the Treasury issued Notice 2015-54 (the Notice) announcing its intent to issue new regulations addressing transactions involving partnerships formed by related parties. According to the...more

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