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Financial Institutions Corporate Taxes

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Fox Rothschild LLP

Changes in Washington State Tax Law Will Impact Businesses

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Washington recently enacted major tax law changes that will affect many businesses operating in the state. Here’s what you need to know: Changes to the Definition of Incidental Investment Income - Washington law now...more

Blank Rome LLP

If You Don’t Ask, The Answer’s Always No

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One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...more

Walkers

The Channel Islands structures being used for infrastructure assets

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We are continuing to see Guernsey and Jersey structures being established for investment into and acquisition of infrastructure assets such as windfarms, network utilities and renewable power....more

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

DLA Piper

Netherlands - VAT: Dutch Attorney General (AG) Issues Conclusion on Impact of Receiving VAT Exempt Interest Income on VAT Recovery...

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Back in November 2023, the Amsterdam High Court ruled that the interest received by X BV (a notary firm) for funds in its trust account qualifies as VAT exempt turnover. According to the High Court, the interest received by X...more

Mayer Brown

Taxe sur les salaires et sociétés « holding » mixtes : une délégation formelle prise par le président est insuffisante pour...

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La cour administrative d'appel de Lyon affirme que l'acte délibératif d’une société indiquant que son président n'exerce aucune fonction de gestion et de contrôle du secteur financier n'exclut pas qu'il exerce un pouvoir de...more

Mayer Brown

La prise en compte des reprises et dotations des provisions pour dépréciation de titres de participation pour le calcul de la...

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Dans une décision mentionnée aux tables du Recueil Lebon, le Conseil d'Etat affirme la légalité de la doctrine administrative du 3 avril 2024, selon laquelle doivent être prises en compte, pour le calcul de la plus-value...more

Conyers

Bermuda Public Companies Update, Winter 2025

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This edition of the Bermuda Public Companies Update summarises significant transactions involving Bermuda companies listed on the New York Stock Exchange and Nasdaq in the second half of 2024. Global Market Update - In...more

A&O Shearman

Autumn 2024: A substantial Labour Budget

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Chancellor of the Exchequer Rachel Reeves delivered Labour’s first Budget since 2010 this week. She made a mark – it was a substantial Budget, effecting tax rises, alongside borrowing and spending commitments, all on a large...more

Adler Pollock & Sheehan P.C.

2024 Rhode Island Legislative Session Report

The Rhode Island General Assembly adjourned sine die on Friday, bringing the 2024 legislative session to a close. Below is an overview of noteworthy legislation passed during the session....more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

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In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Cozen O'Connor

Cozen Currents: Banking on a Crisis

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The Cozen Lens- •This past weekend’s fast-moving banking crisis was an abrupt reminder that the era of easy money is over. While regulators were able to avoid broader contagion (at least for now), this crisis has...more

Proskauer - Tax Talks

President Biden Signs Inflation Reduction Act into Law

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On August 16, 2022 President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law. The IRA includes a 15% corporate alternative minimum tax, a 1% excise tax on stock buybacks and a two-year extension of...more

Davies Ward Phillips & Vineberg LLP

Federal Budget 2022: Tax Highlights

On April 7, 2022 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2022), the second budget since the start of the...more

Dorsey & Whitney LLP

Share Buyback Transactions: U.S. Tax Consequences may differ for each U.S. Shareholder

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On Thursday, November 4, 2021, the Office of the Superintendent of Financial Institutions announced that, subject to approval by the superintendent, Canadian banks and other financial institutions may begin repurchasing their...more

Foodman CPAs & Advisors

2021 “Green Book” Introduces Comprehensive Financial Account Reporting

The “Green Book” is a US Treasury Department document that presents detailed explanations of an Administration’s revenue proposals in support of a President’s annual budget request.  On May 28, 2021, the Biden administration...more

Rivkin Radler LLP

Tax Highlights: The American Families Plan

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In advance of the President’s address to Congress this evening, the White House this morning released a summary of Mr. Biden’s proposed changes to the Internal Revenue Code. These changes, together with his previously...more

White & Case LLP

Spain to tax acquisitions of shares of major Spanish listed companies

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The Spanish Official Gazette published last October 16th legislation enacting a new indirect Tax on Financial Transactions levied, at 0.2%, on the acquisition of shares of major Spanish listed companies irrespective of the...more

Schwabe, Williamson & Wyatt PC

Oregon Department of Revenue Finalizes Second Set of Permanent Oregon Corporate Activity Tax Rules, and Other Tax Updates

Newly Issued Permanent Rules On July 23, 2020, the Oregon Department of Revenue (“DOR”) issued the second set of permanent rules related to the Oregon Corporative Activity Tax (“CAT”). The DOR issued four permanent rules, all...more

Foster Garvey PC

Upcoming CAT Call – Speak Now or Forever Hold Your Peace!

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The Oregon Department of Revenue (“DOR”) announced that it will be conducting a public hearing on June 23, 2020 to discuss a second set of temporary administrative rules relative to the Oregon Commercial Activity Tax (the...more

Foster Garvey PC

More Good News for Oregon Taxpayers – The Oregon Department of Revenue Got It Right

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New guidance from the Oregon Department of Revenue (the “DOR”) with respect to Oregon’s Corporate Activity Tax (“CAT”) was issued Wednesday, May 6th. Specifically, the DOR announced that: - Certain forgivable federal...more

Bracewell LLP

Proposed Rules Addressing LIBOR Phase-out Help Ease Reissuance Concerns

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Since the 2017 announcement that the London interbank offered rate (“LIBOR”) may be phased out after the end of 2021, the municipal finance industry has been concerned that changes to debt obligations and related financial...more

Bradley Arant Boult Cummings LLP

Alabama Legislature Passes Landmark Financial Institution Excise Tax Reform Bill and Forms Corporate Tax Reform Study Group - SALT...

On Tuesday night, May 28, Gov. Kay Ivey signed into law House Bill 419, the Alabama Financial Institution Excise Tax Reform Act of 2019 (FIETRA), which resulted from a collaborative effort between the banking community,...more

Stoel Rives LLP

Oregon Enacts New Corporate Activities Tax

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On May 16, 2019, Oregon Governor Kate Brown signed into law HB 3427 (the Bill), which creates a new Corporate Activities Tax. The tax is a gross receipts tax that will be used to establish the “Fund for Student Success,”...more

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