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Income Taxes International Tax Issues

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... more +
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 -

Bracewell Tax Report: April 2018

by Bracewell LLP on

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, with emphasis on how such developments impact the energy, technology...more

IRS releases Notice 2018-26 - retroactively disregarding certain accounting method changes and entity classification elections

The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

by Carlton Fields on

The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Beyond real estate, other highlights of the new Luxembourg-France tax treaty

by DLA Piper on

The real estate sector was the most immediately impacted by the new Luxembourg-France tax treaty, as we highlighted in our latest alert memorandum....more

Tax newsletter - April 2018

by Hogan Lovells on

In this month's issue of our newsletter on tax matters in Poland: What is new and what is planned in the tax regulations: The extended deadline for the submission of transfer pricing documentation – Regulation of the...more

Foreign-Derived Intangible Income

by Alston & Bird on

It’s probably the next-best part of the Tax Cuts and Jobs Act for multinationals. Our Federal Tax Group investigates the foreign-derived intangible income regime and how you can use it....more

Tax Reform Act Changes to CFC Attribution Rules

The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more

France and Luxembourg Sign New Tax Treaty

by Jones Day on

The Situation: On March 20, 2018, the governments of France and Luxembourg signed a new double tax treaty that will replace the current tax treaty dated April 1, 1958 (as amended through 2014). The Result: The most...more

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

by Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

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

Bracewell Tax Report: February 2018 #2

by Bracewell LLP on

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

High Tax Kickout from GILTI Inclusion for CFC's May Be Too Restrictive

by Charles (Chuck) Rubin on

The new Tax Act added new Code Section 951A. This provision creates a new class of income of a CFC that is taxed currently to U.S. shareholders. That class is "global intangible low-taxed income" or "GILTI." ...more

U.S. Tax Reform – What It Means For The Gaming And Hospitality Industry

by Dickinson Wright on

Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more

UK Tax Round Up - February 2018

by Proskauer Rose LLP on

Case law developments - Settlement payment not deductible as an expense of a trade (Vaines v HMRC) - Mr. Vaines was a solicitor. In the 2007/08 tax year he paid a settlement amount to a third party that had made a...more

Georgia Proposes Response to Federal Tax Reform

by Alston & Bird on

Almost two months since the President signed the Tax Cuts and Jobs Act (TCJA) into law, state legislators across the country are still evaluating the federal tax law’s effects on state revenues and whether to amend state law...more

Connecticut Responds to the Federal Repatriation Tax

by McDermott Will & Emery on

Earlier this month, Connecticut Governor Dan Malloy released his Governor’s Bill addressing the various state tax implications of the federal tax reform bill enacted by Congress in December 2017, commonly referred to as the...more

Tax Considerations for Foreign-Owned U.S. Corporations After 2017 Tax Act

Following the enactment of the 2017 Tax Act, foreign-owned U.S. corporations are, in general, subject to a federal corporate income tax rate of 21% of their world-wide taxable income, as well as to state income taxes that...more

Federal Tax Reform and Minnesota Tax Policy: A Preliminary Guide to Conformity

by Faegre Baker Daniels on

Since the enactment of the Tax Cuts and Jobs Act (TCJA), Minnesota’s Department of Revenue (DOR) has been analyzing what the TCJA will mean for Minnesota. The TCJA marks the most significant changes to the Internal Revenue...more

Tax Reform and Investment Management: Effect on Registered Investment Companies

by K&L Gates LLP on

The Tax Cuts and Jobs Act (“Act”) significantly changed U.S. tax federal law. Although the Act does not amend any of the provisions directly affecting the qualification or other taxation of a “regulated investment company”...more

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

by Foodman CPAs & Advisors on

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

by Foodman CPAs & Advisors on

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

U.S. Taxation Of Foreign Income After Tax Reform

by Farrell Fritz, P.C. on

We’ve all heard about the profits that publicly-held U.S. corporations have generated overseas, and how those profits have, until now, escaped U.S. income taxation by virtue of not having been repatriated to the U.S. It...more

UK Tax Round Up - January 2018

by Proskauer Rose LLP on

The impact of discounts on consideration for VAT purposes (Finanzamt Bingen-Alzey v Boehringer Ingelheim Pharma GmbH & Co. KG) - The ECJ has confirmed that consideration for VAT purposes should be reduced by any discount...more

New U.S. Tax Law Leaves Non-U.S. Person Estate Tax Intact

by Jones Day on

Prior to the passage of the Trump Administration's new tax bill, many had speculated on two key possible impacts for non-U.S. person private wealth bank and brokerage clients—the elimination of the estate tax exemption...more

Update on IRS Offshore Initiatives

by Moskowitz LLP on

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are...more

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