News & Analysis as of

Internal Revenue Code (IRC) Multinationals

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting Domestic and Multinational Businesses

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill). The House Bill will next be considered by the U.S. Senate, and the administration has set a...more

Polsinelli

Hydrocarbon Tax Policy Trends

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As governments focus on clean energy and carbon reduction initiatives, their oil and gas taxation policies have increasingly come under scrutiny. Polsinelli’s attorneys review a few overarching themes concerning expected...more

Latham & Watkins LLP

DOJ Announces Policy Changes to “Invigorate” Efforts to Combat Corporate Crime - Japanese Version

Latham & Watkins LLP on

今回の米国司法省の政策変更において、司法省は個人の責任に一層の重点を置き、また企業の過去の違法行為に対しては包括的な評価を行い、さらに企業との司法解決に対してはより厳格な対応をすることとなる - 2021年10月28日、米国司法省 (United States Department of Justice、以下「DOJ」)...more

McDermott Will & Emery

IRS Issues Transition Tax Compliance Campaign

McDermott Will & Emery on

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more

Orrick, Herrington & Sutcliffe LLP

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Latham & Watkins LLP

Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues

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Introduction and Overview - The Tax Cuts and Jobs Act (“TCJA”) resulted in the most sweeping changes to the Internal Revenue Code (the “Code”) in decades and will result in countless articles and commentary to address the...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

Williams Mullen

Changes Abound in New Tax Bill for Multinational Companies

Williams Mullen on

Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more

Jones Day

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

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The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

A&O Shearman

Trump Administration and Congressional Leaders Release Tax Reform Framework

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On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally...more

Morgan Lewis

Impact of New Tax Regulations on Intercompany Debt Obligations

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The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Cadwalader, Wickersham & Taft LLP

Controversial Debt-Equity Regulations Finalized With Limited Fixes, Concessions and Reservations by Government

On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more

Orrick, Herrington & Sutcliffe LLP

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

Orrick, Herrington & Sutcliffe LLP

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

McGuireWoods LLP

Tax Policy Update

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After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

Dorsey & Whitney LLP

Now’s the Time to Review Compensation Arrangements Relating to Unvested Rights

Dorsey & Whitney LLP on

Correction of Errors before Year End Could Avoid Costly 409A Penalties - Sometimes overlooked is the fact that many employment, severance and change-of-control agreements are subject to U.S. Internal Revenue Code...more

McGuireWoods LLP

Tax Policy Update

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NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

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