News & Analysis as of

Tax Deductions Repatriation

McDermott Will & Emery

BREAKING NEWS: Nebraska Bill Clarifies GILTI and Repatriation Are Deductible

McDermott Will & Emery on

Most states have historically not subjected foreign-source income to state income tax. Consequently, since the passage of TCJA, the vast majority of states have opted not to tax GILTI (with most states explicitly decoupling...more

McDermott Will & Emery

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

McDermott Will & Emery on

On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

McDermott Will & Emery

Connecticut Responds to the Federal Repatriation Tax

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

Eversheds Sutherland (US) LLP

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

Foodman CPAs & Advisors

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

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

Foodman CPAs & Advisors

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

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

Latham & Watkins LLP

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

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

Parker Poe Adams & Bernstein LLP

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

Orrick, Herrington & Sutcliffe LLP

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

Proskauer - Tax Talks

Trump Administration Announces Outline of Its Tax Proposal

Proskauer - Tax Talks on

Yesterday the Trump Administration announced the outline of its tax reform proposal. The proposal combines elements of President Trump’s original tax reform proposal announced during the campaign and of the House Republicans’...more

Seyfarth Shaw LLP

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

Seyfarth Shaw LLP on

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

Gerald Nowotny - Law Office of Gerald R....

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

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