Beginning in 2023, an excise tax of 1% will apply to public company stock buybacks and a 15% corporate minimum tax generally will apply to corporations with book income exceeding $1 billion.
Key Points:
..Public...more
8/22/2022
/ Acquisitions ,
Alternative Minimum Tax ,
Corporate Taxes ,
Derivatives ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
Mergers ,
Multinationals ,
Publicly-Traded Companies ,
Share Buybacks ,
Share Classes ,
Special Purpose Acquisition Companies (SPACs) ,
Stock Options ,
Stock Repurchases
Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct.
On August 6, 2018, the US Tax Court decided...more
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
Administration and Congressional tax negotiators abandon border adjustment tax, but leave unanswered questions regarding rates, revenues, and taxation of US multinationals.
As Congress heads toward its late summer 2017...more