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New Regulations Corporate Taxes

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

McDermott Will & Emery

New From January 2024 | Participation Exemption for European Corporations on Disposal of Shareholdings

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The Italian government recently approved a draft 2024 budget law which provides for the extension of the domestic participation exemption regime on disposal of shareholdings (PEX) to those non-resident corporations that: (i)...more

Eversheds Sutherland (US) LLP

Oregon DOR CAT rulemaking in full swing

With fall rulemaking underway, the Oregon Department of Revenue (DOR) has issued several amendments to, and new regulations related to, Oregon’s Corporate Activity Tax (CAT). On October 27, the Oregon DOR held a public...more

McDermott Will & Emery

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Eversheds Sutherland (US) LLP

Down a rabbit hole: New Jersey regulations provide guidance on GILTI and FDII apportionment

The New Jersey Division of Taxation (Division) quietly issued special regulations addressing the inclusion and apportionment of global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) for...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

McDermott Will & Emery

Final and Proposed BEAT Regulations Provide Some Relief

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Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

McDermott Will & Emery

Weekly IRS Roundup December 2 – 6, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 2 – 6, 2019. December 2, 2019: The IRS issued final regulations providing guidance...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – 22, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

McDermott Will & Emery

Weekly IRS Roundup September 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more

Bracewell LLP

New UAE Economic Substance Regulations Issued

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On 30 April 2019, the UAE Cabinet issued the Cabinet of Ministers Resolution No. 31 of 2019 concerning Economic Substance Regulations in the UAE (“Regulations”). ...more

Mayer Brown

Final Regulations Published Addressing Income Inclusion Rules for Pass-Through Lease of ITC Property

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On July 17, 2019, the US Internal Revenue Service (IRS) issued final regulations (T.D. 9872) providing guidance on the rules under Internal Revenue Code (IRC) section 50(d)(5) requiring an income inclusion by the lessee in...more

Proskauer - Tax Talks

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption – Limits “Deemed Dividends” for U.S. Corporate...

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Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC shareholders. ...more

McDermott Will & Emery

Weekly IRS Roundup May 6 – 10, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more

Nutter McClennen & Fish LLP

Comprehensive Tax Reform in Place as Congress Passes the Tax Cuts and Jobs Act

On December 20, 2017, Congress passed the most extensive package of reforms to the United States income tax system since the overhaul of the tax code in 1986. Enacting tax reform has been a key priority of the Trump...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

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On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Latham & Watkins LLP

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

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Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

BakerHostetler

Proposed Regulations Would Fundamentally Change Treatment of Intra-Group Debt Transactions

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On April 4, 2016, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued two sets of regulations, temporary regulations addressing “inversion” transactions and proposed regulations regarding the...more

Lowndes

New Temporary Inversion Regulations

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The IRS once again is targeting inversions, and this time there have been immediate tangible results. The IRS issued temporary regulations on Monday targeting inversion transactions. An inversion occurs where a foreign...more

McDermott Will & Emery

Six Recommendations For Clients With Connections to France

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There have been a number of changes to EU laws recently that have had, or will have, a direct impact on your clients who have connections with France. There are six stand-out issues that are worth careful and immediate...more

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