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Shearman & Sterling LLP
With the likely increased borrowings or refinancing of debt as a result of the COVID-19 crisis, multinational companies should consider the impact of changes in U.S. tax law made in 2018.
Proskauer Rose LLP
The UK Budget took place on 11 March. In its first post-Brexit Budget with substantial spending announcements, the Treasury wants to continue to ensure the UK remains an attractive and competitive place to invest and do business.
Shearman & Sterling LLP
On February 25, 2020, the United States Supreme Court in Rodriguez v. Federal Deposit Insurance Corporation[1] struck down a judicial federal common law rule
Ropes & Gray LLP
•International Tax Review: Leading Women in Tax Forum: Ropes & Gray is a sponsor of the ITR: Leading Women in Tax Forum on March 3 in New York,...
As business becomes more global, tax authorities worldwide are strengthening compliance regulations, raising fines and demanding more information from corporations that do business internationally.
Holland & Knight
In Part 1, the concept and rationale of tax affecting was discussed.
Davies Ward Phillips & Vineberg
Even after two years of frenzied activity, the IRS has yet to issue several major sets of regulations under the TCJA.
Cleary Gottlieb Steen & Hamilton LLP
The international tax system is continuing to experience a period of significant change
In 2013, the Organisation for Economic Co-operation and Development and G20 countries jointly developed an action plan to address base erosion and profit shifting by multinational enterprises.
Anticipating that the reduction of the corporate tax rate to 21% would result in taxpayers eager to cast aside their S elections in favor of C corporation treatment...
Davies Ward Phillips & Vineberg
The IRS released final and proposed regulations providing further guidance and addressing certain open issues under the base erosion and anti-abuse tax (BEAT).
Ruchelman PLLC
In 2018, charitable giving in the U.S. totaled over $427 billion. Of that amount, 68% of that giving came from individuals, 18% from foundations, 9% from bequests, and 5% from corporations, according to Giving USA.
Dickinson Wright PLLC
The tax code includes a number of provisions that benefit small businesses and small business owners. One of these provisions is contained in Section 1202 which provides for an exclusion of up to 100%
Davies Ward Phillips & Vineberg
Traditionally, taxing jurisdiction has developed on a country-by-country basis.
Cadwalader, Wickersham & Taft LLP
Private debt funds raised more than $100 billion for the fourth consecutive year in 2018,[1] and reached their highest level of fundraising on record during the first half of 2019.[2]
Smith Gambrell & Russell LLP
On September 19, 2019, the IRS issued final regulations updating the rules for hardship withdrawals from 401(k) plans.
Blue J Legal
Few tax incentives are more coveted than tax credits. As dollar-for-dollar tax offsets, tax credits are almost as valuable as cash on hand.
Blue J Legal
As a result, U.S. residents are required to report income earned by controlled foreign corporations, subject to various exclusions.
Morrison & Foerster LLP
After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new apportionment rules
Cadwalader, Wickersham & Taft LLP
The Court of Appeal in The Queen v HMRC [2019] EWCA Civ 1643 (Aozora) recently uphlod the decision of the High Court concerning the extent to which a taxpayer could have a legitimate expectation.
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