Corporate Taxes, Foreign Corporations, Taxation

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

McCarter & English, LLP on 8/5/2025

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

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

Hone Maxwell on 7/30/2025

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

Re-domiciling Companies to Hong Kong

Morrison & Foerster LLP on 6/18/2025

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

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

McDermott Will & Schulte on 5/30/2025

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

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 5/20/2025

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

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

Dorsey & Whitney LLP on 1/31/2025

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

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

White & Case LLP on 6/28/2024

In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

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