News & Analysis as of

International Tax Issues

State Aid in Disguise?—EC Investigates UK Tax Regime

by Jones Day on

The Background: The European Commission has opened an in-depth investigation into a specific provision of the UK-controlled foreign company rules. The Issue: The Commission will investigate whether the UK's so-called Group...more

Seventeen Provisions to Watch in the Senate Tax Reform Bill

On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

by Proskauer - Tax Talks on

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more

Proposed UK Real Estate Tax Regime Targets Offshore Investors' Capital Gains

by Jones Day on

The Situation: Historically, the United Kingdom has not taxed capital gains on real estate disposals when the seller was not a UK resident. The Development: Coming into line with most of the world's jurisdictions, the UK...more

EU “Black Lists” Bahrain and UAE as Non - Cooperative Jurisdiction for Tax Purposes

by King & Spalding on

On 5 December 2017, the Economic and Financial Affairs Council (ECOFIN) determined a list of 17 non-cooperative jurisdictions, which included Bahrain and the United Arab Emirates (UAE). This list was established based on...more

U.S. Tax Reform in Final Stretch

by Hogan Lovells on

This past week, on 1 December, the Senate voted 51-49 to advance its version of U.S. tax reform legislation. This sets the stage for a conference committee process to occur over the next two weeks, in which the Senate and...more

Federal Tax Reform: An Analysis of the House and Senate Bills

by Ballard Spahr LLP on

As we are sure you know, both the U.S. House of Representatives and Senate have passed their own versions of tax legislation, known as the Tax Cuts and Jobs Act. The two different bills will be reconciled in a conference...more

Federal Tax Reform: Side-by-Side Comparison of the Senate and House Approved Bills, Plus the Big Picture

by Ballard Spahr LLP on

Last updated December 5 - The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill,...more

Senate Advances Tax Reform Bill

by Morrison & Foerster LLP on

On December 2, 2017, the Senate passed its version of tax reform legislation (the "Senate Bill"), advancing it to the next stage. While the House of Representatives passed its version of tax reform (the "House Bill") on...more

Senate Passes Tax Reform Bill

by Dechert LLP on

The U.S. Senate passed its version of the GOP tax reform bill, the Tax Cuts and Jobs Act (the “Senate Bill”), on Saturday, December 2, 2017. Shortly before approving the Senate Bill, the U.S. Senate adopted a Manager’s...more

Tax Alert Regarding The Impact Of The House And Senate Tax Bills On International Taxation

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act, and later proposed amendments to the bill on November 3, November 6, and November 9,...more

Federal Tax Reform: The Current State of Play & The Big Picture (Updated 12/5)

by Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

Tax Cuts and Jobs Act

by Kelley Drye & Warren LLP on

The U.S. Senate passed the “Tax Cuts and Jobs Act” early Saturday. The House of Representatives passed its version of this tax legislation on November 16th. The House and Senate will now begin the process of reconciling...more

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Tax Cuts and Jobs Act Update: Senate Approval Moves Bill Forward

by Polsinelli on

The Senate passed a version of the Tax Cuts and Jobs Act that differs significantly from the House-passed bill but still contains several similar proposals that lower individual and business tax rates, completely revamp the...more

Senate Passes Tax Bill - What Did They Change?

On November 9th, the Joint Committee on Taxation released the Description of the Chairman’s Mark of the Tax Cuts and Jobs Act, revealing the Senate’s version of proposed tax reform. On December 2, 2017, the Senate passed a...more

Tax Reform Bills Seek Largest Restructuring of Tax Code in More Than a Generation

On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act. The Senate Budget Committee voted on Nov. 28, 2017, to send the Senate version of the bill to the floor,...more

UK Tax Round Up - November 2017

by Proskauer Rose LLP on

UK Tax News and Developments - The OTS publishes its report "Value added tax: routes to simplification" - On 7 November, the Office of Tax Simplification (OTS) published its first report on VAT, which included a range...more

India publishes new rules for master file and CbC reporting

by DLA Piper on

Acting on its commitment to the OECD BEPS Action Plan, India has published the final guidance in relation to the requirements of multinationals to provide master file and country-by-country (CbC) reporting in India. The...more

Estate Planning Under the Tax Cuts and Jobs Act

If enacted, the Tax Cuts and Jobs Act could open up significant estate planning opportunities. The House bill doubles the exemptions from estate, gift and generation-skipping transfer taxes, creating new opportunities for...more

UK Budget 2017 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2017 on 22 November 2017. Delivered against the backdrop of the UK’s ongoing negotiations to exit from the European Union, the Budget featured a significant...more

Tax Reform Executive Summary – A 2-Pager on the 7 Things You Need to Know

Tax reform efforts, if successful, will have a major impact on virtually every business. There has been a great deal of reporting on the tax reform process and the proposed changes to the US Internal Revenue Code (IRC). This...more

Worldwide Territoriality: International Tax Proposals Broaden the Base

On November 16, 2017, the House of Representatives passed a much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The passage of the House Plan...more

Senate Finance Committee Releases Its Version of the Tax Cuts and Jobs Act

After releasing summaries and various Chairman's marks, the Senate Finance Committee ("SFC") approved its tax reform bill, the "Tax Cuts and Jobs Act," on November 16, 2017 and released the legislative text of the bill to the...more

Proposed tax legislation affecting private equity

by Dentons on

As you may be aware, on November 2 the House of Representatives introduced a comprehensive tax reform bill that could affect private equity sponsors, investors and portfolio companies. On November 9, the Senate Finance...more

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