News & Analysis as of

Repatriation

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

How will Georgia conform to federal tax reform? Annual legislation introduced

The Georgia Legislature has introduced its annual Internal Revenue Code (IRC) conformity bill—HB 821. Georgia conformity is typically updated annually to apply for the most recent tax year. In light of the recently enacted...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

Tried and trusted: US M&A in 2017: US M&A survey: Drivers, dilemmas and destinations

by White & Case LLP on

Our exclusive survey identifies impacts from tax reforms and the repatriation of offshore capital as key areas to watch in 2018. Digital innovation remains a major driver for transactions, while effective due diligence poses...more

IRS, Treasury Issue Guidance on Section 965 Deemed Repatriation Rules, Signal Important Form 5471 Exception

by Morgan Lewis on

Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders will be permitted to elect...more

IRS Issues Guidance for New Repatriation Tax

Many U.S. owners of foreign companies are surprised to hear that the new repatriation tax not only applies to “repatriated” foreign earnings, but also to foreign earnings that are not repatriated into the U.S. They are even...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

NYSE owner Intercontinental Exchange is looking to do the as-yet inconceivable: bring some order to cryptocurrencies. The plan, announced yesterday, is to launch a data feed that pull info from cryptocurrency exchanges around...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

The Dow closed above 26k yesterday for the first time on what some are dubbing the FOMO rally or the “melt-up” market....more

Tax Act: Significant International Provisions

by WilmerHale on

Prior to the Tax Act, the principal method for avoiding the double taxation of overseas corporate earnings—once by the local country and a second time by the United States as the multinational's home country—was the foreign...more

Deemed Repatriation of Foreign Deferred Income May Decrease State Taxable Income

by Stoel Rives LLP on

A revenue raising provision in the recently enacted federal tax reform legislation, the Tax Cuts and Jobs Act (the Act), may have an unintended consequence of decreasing a taxpayer’s state taxable income because of the way...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

by Latham & Watkins LLP on

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

Changes Abound in New Tax Bill for Multinational Companies

by 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

How Will Federal Tax Reform Impact Your Business in 2018 and Beyond?

On December 22, 2017, the U.S. enacted the largest overhaul of the federal tax code in more than three decades. This legislation introduces sweeping changes to the U.S. taxation of individuals and businesses....more

Tax Cuts and Jobs Act could have significant impact on structuring of US and foreign investments

by DLA Piper on

The Tax Cuts and Jobs Act (the New Tax Law), signed into law in late December by President Donald Trump, makes major permanent and temporary changes to the US federal tax system. The changes will have a significant impact on...more

IRS Provides Guidance on Tax Reform’s New § 965 Deemed Repatriation Provision

by Morgan Lewis on

It answers some questions but leaves many issues unresolved. On December 29, the US Internal Revenue Service (IRS) issued Notice 2018-07—Guidance under Section 965 (the Notice)—indicating its intent to issue regulations...more

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

U.S. Tax Reform Bill Passes Both Houses; Awaits President's Signature

by Morrison & Foerster LLP on

On December 20, 2017, both the House and the Senate passed H.R. 1 (the “Bill”), which President Trump is expected to sign by January 3, 2018. The Bill dramatically alters the U.S. approach to domestic and international...more

State Tax Implications of the Repatriation Transition Tax and the GILTI

by McDermott Will & Emery on

While some of the international tax provisions set forth in the current federal tax bill are complex from a federal tax perspective, layering on state tax implications not only adds intricacy, but also a great amount of...more

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

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

Five Things to Know about the Tax Cuts and Jobs Act

Even with the bill still in Conference, here are some things businesses should follow closely. Both House and Senate Bills call for deemed repatriation of accumulated foreign profits at reduced tax rates. ...more

Estate Planning Pitfall - You’re retiring to a foreign country

If plans call to relocate to another country after retirement, be aware that they may be tarnished if a person doesn’t look into all potential estate tax and income tax implications first. This brief article explores three...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

Deemed Dividends Under Proposed Tax Reform

by Miles & Stockbridge P.C. on

2017 tax reform efforts may alleviate adverse deemed dividend tax treatment of foreign subsidiary support for the obligations of U.S. parent companies. Present support is limited to the pledge of 66 ?rds of the stock in...more

Notes on the Financial Surveillance Special Voluntary Disclosure Programme process

by Hogan Lovells on

The Financial Surveillance Special Voluntary Disclosure Programme (the FinSurv SVDP) was announced by the Minister of Finance in the February 2016 Budget Speech....more

74 Results
|
View per page
Page: of 3
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.