The insertion of a US holding company by way of a share-for-share exchange, whereby the shares in an existing UK company (“UKCo”) are transferred to a new US company (“USCo”) in exchange for shares issued by USCo, is commonly...more
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
12/29/2017
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Foreign Tax Credits ,
Income Taxes ,
International Tax Issues ,
Legitimate Business Interest ,
New Legislation ,
Pass-Through Entities ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Deferral ,
Tax Rates ,
Tax Reform ,
Trump Administration