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Tax Deductions Foreign Investment

International Lawyers Network

Establishing a Business Entity in the United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more

K&L Gates LLP

Australian Federal Budget 2023-2024 - Key Tax Measures and Instant Insights

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The Australian Federal Government has just released its budget for 2023-24. The K&L Gates tax team outlines the key announced tax measures and our instant insights into what they mean for you in practice....more

Paul Hastings LLP

Thin Capitalization Tax Rules Finally Applied in Court —Tokyo District/High Courts Deny Tax Deductibility of Interest Paid to a...

Paul Hastings LLP on

The thin capitalization tax rules (the “Thin Capital Rules” or the “Rules”) were incorporated into our tax statute in 1992. Then no cases appeared in courts for almost three decades. Recently, however, a new case appeared in...more

International Lawyers Network

Establishing A Business Entity In The United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...more

Bennett Jones LLP

Canada Introduces "Excessive Interest and Financing Expenses Limitation"

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Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Bennett Jones LLP

The 2018 Federal Fall Economic Statement—Canada's Response to U.S. Tax Reform

Bennett Jones LLP on

Roughly one year after U.S. tax reform, the Department of Finance has introduced amendments to Canada's income tax laws aimed at encouraging investment in Canada. The proposed changes included in the Fall Economic Statement...more

Hogan Lovells

French legal and regulatory update – July to October 2018

Hogan Lovells on

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e - newsletter, which offers a legal and regulatory update covering France and Europe from July to October 2018. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more

Orrick, Herrington & Sutcliffe LLP

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

McDermott Will & Emery

The New Deduction for Foreign-Derived Intangible Income

McDermott Will & Emery on

The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more

Orrick, Herrington & Sutcliffe LLP

How Tax Reform Could Trigger Significant Taxes For Unwary Stockholders (And Funds) In Foreign Companies

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). - Statutory language of the Bill may cause an unexpected tax hit on unwary U.S. stockholders who...more

Mintz

Proposed U.S. Tax Reform May Impact Investments in U.S. Real Estate

Mintz on

Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more

McDermott Will & Emery

M&A Tax Aspects of Republican Tax Reform Framework

McDermott Will & Emery on

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a...more

Hogan Lovells

Trends in cross-border real estate investment and the changing tax landscape

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Real estate markets in both the U.S. and Europe continue to attract significant overseas investment. With interest rates at or near all-time lows, and dwindling returns in other asset classes, real estate has emerged as...more

Jones Day

Further Update on Federal Taxation - Australian Infrastructure Investment and Privatisation

Jones Day on

Last month, we reported in our White Paper on taxation proposals directed at infrastructure and utility privatisation transactions. Since we wrote, the Commonwealth Treasury ("Treasury") has published a policy paper directed...more

Proskauer Rose LLP

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

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On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more

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