Income Taxes, Corporate Taxes, Foreign Corporations

El IRS actualiza reglas sobre los ajustes a la base gravable en las distribuciones a mitad de año por las CFC para evitar las...

Freeman Law on 6/12/2024

Durante años, había existido incertidumbre entre los profesionistas que se dedican a la materia fiscal sobre sobre si las ganancias obtenidas a mitad de año por una Corporación Extranjera Controlada (por sus siglas en inglés,...more

Balancing Uncle Sam’s Checkbook: Biden’s Tax Proposals

Cadwalader, Wickersham & Taft LLP on 3/29/2024

In President Biden’s recent State of the Union Address, he called on corporations and wealthy taxpayers to pay their “fair share” through proposals to end tax breaks for private jets, further limit deductions for executive...more

Establishing a Business Entity in Spain (Updated)

International Lawyers Network on 3/5/2024

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Establishing a Business Entity in Singapore (Updated)

International Lawyers Network on 2/29/2024

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

Establishing a Business Entity in New Zealand (Updated)

International Lawyers Network on 2/22/2024

TYPES OF BUSINESS ENTITIES - There are various entities available in New Zealand from which a business can be operated. The most commonly adopted entities are: 1. Company (including Incorporated Joint Venture (JVC))...more

Establishing a Business Entity in Malta (Updated)

International Lawyers Network on 2/14/2024

Introduction - With its corporate laws based upon those of the UK, Malta has incorporated laws and principles into its own legislation, providing comfort and security to the commercial and business community. The most...more

Establishing a Business Entity in Germany (Updated)

International Lawyers Network on 1/22/2024

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

Establishing a Business Entity in Brazil (Updated)

International Lawyers Network on 12/18/2023

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more

Establishing a Business Entity in Austria (Updated)

International Lawyers Network on 12/11/2023

1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more

GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint

Skadden, Arps, Slate, Meagher & Flom LLP on 12/8/2023

Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more

Establishing a Business Entity in Argentina (Updated)

International Lawyers Network on 12/7/2023

Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more

IRS Announces New Compliance Initiatives to Collect More Corporate Tax Using Inflation Reduction Act Funds

McDermott Will & Emery on 10/24/2023

On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more

Pin-pointing Residence

Cadwalader, Wickersham & Taft LLP on 8/24/2023

The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more

Dividend income is excluded from the EBITDA for the purpose of the Spanish interest limitation rule

Hogan Lovells on 6/1/2023

The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more

Ways and Means Committee Republicans Release Pillar Two Remedies Proposal

Brownstein Hyatt Farber Schreck on 5/26/2023

House Ways and Means Committee Chairman Jason Smith (R-MO) and committee Republicans released legislation on May 25, 2023, in response to the Pillar Two global minimum tax negotiated by the Organisation for Economic...more

Establishing A Business Entity In Spain (Updated)

International Lawyers Network on 3/29/2023

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Establishing A Business Entity In Singapore (Updated)

International Lawyers Network on 3/23/2023

Registration of Business Entities - Unless exempted, business entities must be registered with the Accounting and Corporate Regulatory Authority (ACRA) via their business filing portal: BizFile+. A foreigner residing...more

Establishing a Business Entity in Greece (Updated)

International Lawyers Network on 2/17/2023

1. Types of Business Entities - The main business entities in Greece are the following: i) the Société Anonyme (S.A.); ii) the Private Company (P.C.); iii) the Limited Liability Company (Ltd); iv) the General Partnership...more

Establishing a Business Entity in Germany (Updated)

International Lawyers Network on 2/16/2023

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

Reviewing a Foreign Legal Structure

Freeman Law on 1/25/2023

Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more

Establishing A Business Entity In Brazil (Updated)

International Lawyers Network on 1/17/2023

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more

Establishing A Business Entity In Austria (Updated)

International Lawyers Network on 1/6/2023

In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability companies and joint-stock...more

Establishing a Business Entity in Argentina (Updated)

International Lawyers Network on 1/4/2023

Types of business entities - The two most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”) and the corporation (“Sociedad Anónima” or...more

Tax Court in Brief | Ismail v. Comm’r | Foreign LLC for U.S. tax purposes; Substantiation of Schedule C Expenses; Section 274

Freeman Law on 1/3/2023

Short Summary: The case discusses the tax classification of a foreign corporation for U.S. tax purposes and the substantiation of various business expenses such as vehicle, travel, and meals and entertainment expenses....more

Section 245A Overview and Requirements

Freeman Law on 10/21/2022

Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings - Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...more

Income Taxes › Corporate Taxes › Foreign Corporations

"My best business intelligence, in one easy email…"