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Tax Reform Repatriation

McDermott Will & Emery

Weekly IRS Roundup January 13 – 17, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13 – 17, 2020. January 13, 2020: The IRS published an information letter relating to the...more

Holland & Hart LLP

Utah Legislative Update: Summer 2018

Holland & Hart LLP on

Governor Gary Herbert called the Utah Legislature into a July Special Session. July is often a month when the Utah legislature takes a break from meetings due to the Independence Day and Pioneer Day holidays bookending the...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

Foley & Lardner LLP

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

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

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

Morgan Lewis

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

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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

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

Morrison & Foerster LLP

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

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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

Sheppard Mullin Richter & Hampton LLP

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

Morrison & Foerster LLP

Senate Advances Tax Reform Bill

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

Miles & Stockbridge P.C.

Deemed Dividends Under Proposed Tax Reform

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

A&O Shearman

House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

A&O Shearman on

On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

Jones Day

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

Jones Day on

The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more

Proskauer - Tax Talks

Trump Administration Announces Outline of Its Tax Proposal

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways: Prospects for US Business Tax Reform — What You Need to Know

On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways: Inside the White House and Capitol Hill — The Impact of a New Administration on Global Markets

On January 25, 2017, Skadden hosted a panel discussion at the London Stock Exchange on the potential policy direction of the Trump administration. The panel touched on tax reform, trade agreements, inbound and outbound U.S....more

Baker Donelson

President Trump Has Been Inaugurated. What's Next for Tax Reform?

Baker Donelson on

President Donald J. Trump has just been inaugurated as the 45th President of the United States and his proposals regarding tax reform played a key role throughout his entire presidential campaign. Because Republicans retained...more

Kramer Levin Naftalis & Frankel LLP

Tax Reform in the New Administration

The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...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

Butler Snow LLP

Is Tax Reform On the Horizon?

Butler Snow LLP on

2017 will bring Republican control to D.C. It will also potentially bring tax reform. Both President Elect Donald Trump and House Republicans have proposed sweeping changes to the U.S. tax system, which we have briefly...more

Bennett Jones LLP

What Trump’s Tax Plan Means For Canada

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The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely. The specifics of that reform are not known but the...more

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