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International Tax Issues

Bracewell Tax Report - March 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 (TCJA), with emphasis on how such developments impact the energy,...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

Shareholders of S Corps can defer payment of Transition Tax

by Foodman CPAs & Advisors on

The Tax Cuts and Jobs Act (TCJA) includes 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

Saudi Arabia VAT Guide

by DLA Piper on

The Kingdom of Saudi Arabia (the "KSA") has introduced Value Added Tax (VAT) with effect from 1 January 2018, in accordance with the framework agreement among Gulf Cooperation Council (the "GCC") Member States, known as the...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

Regulatory Monitor: Private Funds Update

by K&L Gates LLP on

The Tax Cuts and Jobs Act – Material Impact on Private Funds - On December 22, 2017, the president signed the tax reform bill formerly known as the Tax Cuts and Jobs Act (the TCJA). While the TCJA will impact many types of...more

Private Funds Update - February 2018

by Bracewell LLP on

SEC's OCIE Announces 2018 Examination Priorities - ...On February 7, 2018, the Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released its 2018 examination...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

The Effect of Tax Reform on Financing Transactions: Thoroughly Review Your Company's Situation

by Foley & Lardner LLP on

In general, the effects of the new tax law should be very favorable to most corporate borrowers. Nevertheless, there may be situations where a corporate borrower benefits economically from a lower tax rate and other favorable...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

Indian Maternity Benefit (Amendment) Act, 2017

Under a newly amended law, many employers in India are required to increase paid maternity leave and offer on-site day care services; some of the new standards await clarification. Providing crèche (day care) facilities is...more

EU: “Hard” Brexit Would Come with Border Friction and Costs

The European Union has published a technical note warning of dire consequences for businesses if the UK leaves the EU with no deal in place. The European Commission has warned companies across Europe to prepare for...more

Gaming & Hospitality Legal News: Volume 11, Number 2 - The More Things Change, The More They … Change: Recent Developments In...

by Dickinson Wright on

Executive Summary and Takeaway: Trade secrets and confidential information are receiving increasing protection in many states, and as more states perceive this as a "business friendly" issue, this trend will continue and...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

Bracewell Tax Report: February 2018

by Bracewell LLP on

The Tax Cuts and Jobs Act (TCJA) effected sweeping reform across the Internal Revenue Code. This report, and future installments, will discuss this legislation and other important tax guidance, including how such authorities...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

Inexplicably, Section 956 Survives Tax Reform Intact

by Alston & Bird on

How did a section of the Internal Revenue Code destined for repeal by both the House and Senate versions of the Tax Cuts and Jobs Act survive the final Act? Our International Tax Group examines the future application of...more

US “TCJ Act” Tightening of CFC Rules Eliminates Common Approach To Post-Death Avoidance Of US Beneficiary Taxation

by Bryan Cave on

On December 22, 2017, President Trump signed into law H.R. 1 (Pub. L. No. 115-97), known as the Tax Cuts and Jobs Act (the “Act”). The Act is the first major overhaul of the Internal Revenue Code (the “Code”) in more than 30...more

China’s Greater Bay Area Puts Hong Kong In The Lead As Super Connector To The World

by Dorsey & Whitney LLP on

China’s open door policy is further opening up to welcome the world for business. The country is now building a landmark megalopolis on its southern coast with the name the “Greater Bay Area” (the “GBA”). ...more

Impact of Recent Tax Legislation on M&A Transactions

by 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

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

2018 EU Trade, Regulatory and Competition Trends

Our “trends for 2018” are only a selection of interesting developments to watch for in 2018. Within the political and legislative cycle of the European Union, 2018 promises to be an eventful year, given that it is the last...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

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