In Short -
The Situation: On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 into law. The Act establishes a new 15% corporate minimum tax (the "CMT") on large U.S. corporations (generally...more
In Short -
The Situation: On August 16, 2022, the Inflation Reduction Act of 2022 (the "Act") was signed into law, enacting a new nondeductible 1% excise tax on certain share repurchases (so-called "stock buybacks"). ...more
The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question gave rise to a selective advantage under EU...more
7/21/2020
/ Apple ,
BEPS ,
Corporate Taxes ,
EU ,
European Commission ,
Fiat ,
Government Investigations ,
Member State ,
OECD ,
Popular ,
Starbucks ,
State Aid ,
Transfer Pricing ,
Treaty on the Functioning of the European Union (TFEU)
The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations.
The Development:...more
6/25/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Tax ,
GILTI tax ,
IRS ,
Multinationals ,
New Rules ,
Partnerships ,
Proposed Regulation ,
Retroactive Taxes ,
Stocks ,
U.S. Treasury
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
Signed into law December 22, 2017, the "Tax Cuts and Jobs Act" represents the most comprehensive reform to the U.S. federal tax code in a generation. The Act's most notable provisions include significant reductions in both...more
1/16/2018
/ Affordable Care Act ,
Alternative Minimum Tax ,
Base Erosion Tax ,
Business Taxes ,
Corporate Taxes ,
Estate Tax ,
FIFO ,
Foreign Earned Income ,
International Tax Issues ,
Net Operating Losses ,
New Legislation ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more
11/7/2017
/ Acquisitions ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Death Tax ,
EBITDA ,
Excise Tax ,
Executive Compensation ,
Foreign Corporations ,
Foreign Earned Income ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Itemized Deductions ,
MACRS ,
Mortgage Interest ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
Principal Executive Officer ,
Proposed Legislation ,
REIT ,
Section 409A ,
Shareholders ,
Subpart F ,
Tax Credits ,
Tax Deductions ,
Tax Reform ,
Transfer Taxes ,
Trump Administration ,
Ways and Means Committee
The Situation: The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws....more
10/11/2017
/ Alternative Minimum Tax ,
Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
Family Businesses ,
Foreign Subsidiaries ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
Multinationals ,
Pass-Through Entities ,
Proposed Legislation ,
Repatriation ,
S-Corporation ,
Tax Rates ,
Tax Reform ,
Trump Administration
On April 26, 2017, the Trump Administration officially announced the President's tax reform plan in a one-page proposal calling for substantial business and individual tax cuts and the elimination of the AMT and many...more