Corporate Taxes, Offshore Companies

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on 2/5/2024

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on 11/29/2023

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

Orrick, Herrington & Sutcliffe LLP on 6/21/2019

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

New Offshore Economic Substance Rules Could Spell Significant Concern for PE Funds and Bermuda/Cayman/BVI-Based Structures

Orrick, Herrington & Sutcliffe LLP on 4/30/2019

Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more

IRS Extends Date for Section 965 Liability Transfer Agreement

Orrick, Herrington & Sutcliffe LLP on 10/16/2018

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

Treasury Provides Details on Transition Tax

Jones Day on 8/16/2018

Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform. On August 1, 2018, proposed...more

Section 965 Proposed Regulations Issued

Butler Snow LLP on 8/3/2018

On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a...more

Corporate Inversions

Kelley Drye & Warren LLP on 7/19/2017

A multinational corporate group headed by a U.S. parent corporation is often at a competitive disadvantage compared to a multinational corporate group headed by a foreign corporation. While a multinational corporate group...more

Corporate Taxes › Offshore Companies

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