News & Analysis as of

EBITDA Corporate Taxes

Davies Ward Phillips & Vineberg LLP

Major U.S. Tax Legislation Enacted Without Retaliatory Tax Provision

This bulletin follows our previous update on evolving U.S. tax reform, which highlighted the competing House and Senate proposals, particularly the introduction and scope of proposed Section 899 targeting "unfair foreign...more

Paul Hastings LLP

REIT All About It: One Big Beautiful Bill — Tax Updates for REITs

Paul Hastings LLP on

On July 4, 2025, President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law, following the approval of Congress. OBBBA contains the following compelling updates from a real estate investment trust (REIT)...more

Goodwin

One Big Beautiful Bill Act - Tax Highlights Related to Real Estate Investors

Goodwin on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA), which both extends many soon-to-expire provisions of the Tax Cuts and Jobs Act of 2017 (TCJA) and makes several additional changes to the...more

Goodwin

One Big Beautiful Bill Act - Tax Highlights related to Research and Experimental Expenditures, Qualified Small Business Stock and...

Goodwin on

On July 4, 2025, the One Big Beautiful Bill Act (OBBB) was signed into law. The OBBB extends various expiring tax provisions from the Tax Cuts and Jobs Act (TCJA) and introduces a variety of other substantial tax law changes....more

Skadden, Arps, Slate, Meagher & Flom LLP

Senate Finance Committee Proposes Key Departures From House Provisions for the One Big Beautiful Bill Act

Key Points - - The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent. - The bill...more

Baker Botts L.L.P.

"The One Big Beautiful Bill" Key Tax Takeaways

Baker Botts L.L.P. on

On May 22, 2025, the House passed the legislation entitled “The One Big Beautiful Bill” (the “BBB”). The BBB makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts and Jobs Act...more

Sullivan & Worcester

How REITs are Impacted by the “One Big Beautiful Bill Act”

Sullivan & Worcester on

The U.S. House of Representatives, by a one-vote margin, passed the “One Big Beautiful Bill Act” (the “House Bill”) early in the morning on May 22, 2025. The House Bill has yet to be considered by the U.S. Senate and will...more

Eversheds Sutherland (US) LLP

House confirms favorable modifications to three key business tax provisions

On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more

Latham & Watkins LLP

Lexology In-Depth - Acquisition And Leveraged Finance

Latham & Watkins LLP on

It was a muted start to the year for the acquisition and leveraged finance market due to a challenging macroeconomic climate. Interest rate hikes at one of the fastest paces on record, surging inflation (particularly in...more

Hogan Lovells

Dividend income is excluded from the EBITDA for the purpose of the Spanish interest limitation rule

Hogan Lovells on

The Spanish interest limitation rule establishes that net financial expenses are deductible for Spanish Corporate Income Tax ("CIT”) purposes with the annual limit of the higher of (i) 30% of the Tax EBITDA (as defined in the...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Goodwin

Luxembourg Tax Authorities Issue Administrative Guidance On Application Of Interest Limitation Rules

Goodwin on

On 8 January 2021, the Luxembourg Tax Authorities published a Circular clarifying the interest limitation rules introduced in Luxembourg legislation in 2018, which implemented the European Union Anti-Tax Avoidance Directive...more

Goodwin

Luxembourg Circular On Interest Limitation Rules

Goodwin on

On 8 January, 2021, the Luxembourg tax authorities published Circular L.I.R. 168bis/1 on interest limitation rules (the “Circular”). The Circular provides much needed clarity to the interest limitation rules which have...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Skadden, Arps, Slate, Meagher & Flom LLP

Lessons From 2019: Impact of BEPS on Cross-Border Transactions

In 2019, a number of common themes emerged from cross-border transactions that have continued to demonstrate the impact of the 2014 Base Erosion and Profit Shifting (BEPS) actions. These themes, which we anticipate will gain...more

Wilson Sonsini Goodrich & Rosati

Corporate Tax 2019 - Seventh Edition - USA Chapter

Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more

King & Spalding

Renewed Interest in Synthetic Leases - A Refresher and Changes Under the New (ASC 842) Lease Accounting Standard

King & Spalding on

A synthetic lease is a financing technique structured to be an operating lease for the lessee’s financial accounting purposes and a financing for U.S. federal tax purposes. Synthetic leases are most often used in acquisition...more

Womble Bond Dickinson

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Womble Bond Dickinson on

Background on the Anti-Tax Avoidance Directive - On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. ATAD is the European Commission’s response to the relevant Action...more

K&L Gates LLP

French Finance Act for 2019: The Most Important Changes Affecting Businesses

K&L Gates LLP on

The French Finance Act for 2019 was enacted on December 28, 2018 (the “Act”). The Act introduces significant changes to the interest deduction rules and to the favorable tax regime applicable to Industrial Property (“IP”)...more

Akin Gump Strauss Hauer & Feld LLP

European Tax Update January 2019

We set out below a recap of some of the key European and international tax developments to note at the start of 2019. This alert provides a brief summary of the following...more

A&O Shearman

Government Issues Proposed Regulations on Business Interest Expense Deduction Limitation: Overview and Impact on Leveraged Finance...

A&O Shearman on

On November 26, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated regulations regarding the new section 163(j) limitation on business interest deductions. Section 163(j) was modified as...more

Foley & Lardner LLP

2018 Private Equity Industry Overview

Foley & Lardner LLP on

Private equity firms entered 2018 amid a confusing mix of record inflows and elevated prices. At the same time, new regulation was expected to raise the cost of capital while also reducing taxes, rolling back limits on...more

Orrick, Herrington & Sutcliffe LLP

Frances Draft 2019 Finance Bill Reforms Interest Deductibility Limitation Rules

The French government presented the draft Finance Bill for 2019 on September 24, 2018. This draft is currently being discussed by the Parliament and is subject to potential changes....more

Jones Day

Draft French Finance Bill for 2019 Reveals Significant Tax Amendments

Jones Day on

The Situation: The first draft of the French government's finance bill for 2019 contains several significant amendments likely to affect key French tax regimes, as well as past and current transactions. The Development:...more

McDermott Will & Emery

Interaction of Interest Limitation Rules in the United States and Elsewhere

McDermott Will & Emery on

Until recently, the high US corporate tax rate and regime governing interest deductibility had provided a clear incentive for multinationals (particularly, non-US multinationals) to push interest expense into the United...more

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