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Corporate Taxes Foreign Corporations

McCarter & English, LLP

Recent Amendments to the General Corporation Law of the State of Delaware

On August 1, 2025, legislation went into effect amending the Delaware General Corporation Law (DGCL) of the state of Delaware as contained in Senate Bill No. 95. The following is a brief summary of some of the more...more

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

Hone Maxwell on

Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Cooley LLP

Key International Tax Provisions Under the One Big Beautiful Bill Act

Cooley LLP on

On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. It is a landmark piece of legislation that introduces several important changes to the US international tax regime. This alert provides an overview...more

Latham & Watkins LLP

One Big Beautiful Bill Introduces Major Changes to Federal Tax Law

Latham & Watkins LLP on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBB) into law, making permanent the reduced individual tax rates and brackets established by the Tax Cuts and Jobs Act of 2017 and modifying a...more

Bilzin Sumberg

Key International Tax Changes From the One Big Beautiful Bill Act

Bilzin Sumberg on

On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more

Mayer Brown Free Writings + Perspectives

One Big Beautiful Bill Act Introduces Significant Domestic and International Tax Changes

On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and...more

Morrison & Foerster LLP

Re-domiciling Companies to Hong Kong

From May 23, 2025, companies may transfer their domicile to Hong Kong under a new regime which will allow them to preserve their legal identity and will not interrupt business operations. To qualify, companies must meet...more

Seyfarth Shaw LLP

Hong Kong Launches Company Re-domiciliation Regime

Seyfarth Shaw LLP on

In a move to enhance Hong Kong’s status as a global business and financial hub, and to attract foreign companies to take advantage of Hong Kong’s taxation system and professional services–thereby encouraging investment and...more

McGuireWoods Consulting

Corporate Tax Changes In Illinois FY 2026 Budget Package

The 2025 regular session of the Illinois General Assembly adjourned on June 1, 2025. The General Assembly passed a fiscal year (FY) 2026 budget package which includes corporate tax changes that will significantly impact...more

International Lawyers Network

Establishing a Business Entity in Kenya (Updated)

a) Types of business entities in Kenya - Kenya has 5 main types of business entities that is, sole proprietorships, partnerships, limited liability partnerships, companies, non-governmental organizations and trusts. A...more

McDermott Will & Schulte

The Proposed US Tax Regime for Non-US Investors and Companies

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Mintz - Tax Viewpoints on

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Hogan Lovells

New Section 899 – Enforcement of remedies against unfair taxes

Hogan Lovells on

On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more

International Lawyers Network

Establishing a Business Entity in Malta (Updated)

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

International Lawyers Network

Establishing a Business Entity in Kenya (Updated)

[co-author: Mourice Okon] a) Types of business entities in Kenya - Kenya has 5 main types of business entities that is, sole proprietorships, partnerships, limited liability partnerships, companies, non-governmental...more

International Lawyers Network

Establishing a Business Entity in Hong Kong (Updated)

ESTABLISHING A BUSINESS ENTITY IN HONG KONG - 1. Introduction - Hong Kong as an international centre for finance, commerce and trade is often considered as one of the most attractive places to do business owing to its...more

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

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...more

Fenwick & West LLP

U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

Dorsey & Whitney LLP on

Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

International Lawyers Network

Establishing a Business Entity in the Czech Republic (Updated)

1. Types of business entities - Investors may choose from the following forms of corporate structure: - Limited liability company - Joint-stock company - Limited liability partnership - General partnership -...more

International Lawyers Network

Establishing a Business Entity in Cyprus (Updated)

Introduction - Cyprus is an EU member state and a common law jurisdiction with a legal system similar to that of the UK. It is located at the eastern end of Europe linking 3 continents, Europe, Africa and Asia and it has...more

International Lawyers Network

Establishing a Business Entity in Costa Rica (Updated)

1. Types of Business Entities in Costa Rica - The most common types of business entities in Costa Rica are Corporations, known in Spanish as “Sociedades Anónimas” (also referred to as “S.A.´s”), and Limited Liability...more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

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

McDermott Will & Schulte

Five Key Takeaways From the Proposed PTEP Regulations

McDermott Will & Schulte on

Taxpayers have been eagerly awaiting, and the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have been promising to provide, rules addressing the previously taxed earnings and profits (PTEP)...more

Hogan Lovells

Establishment of a business in the United Kingdom by a foreign corporation (UPDATE)

Hogan Lovells on

This note describes in outline the laws and taxes which currently apply to a foreign corporation establishing a business operation in the United Kingdom and the administrative requirements which need to be observed once the...more

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