Shareholders, Tax Reform, Foreign Corporations

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on 6/19/2025

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

Balancing Uncle Sam’s Checkbook: Biden’s Tax Proposals

Cadwalader, Wickersham & Taft LLP on 3/29/2024

In President Biden’s recent State of the Union Address, he called on corporations and wealthy taxpayers to pay their “fair share” through proposals to end tax breaks for private jets, further limit deductions for executive...more

Challenging Tax Cuts and Jobs Act Regulations and IRS Guidance

Skadden, Arps, Slate, Meagher & Flom LLP on 1/27/2020

The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more

The Tax Cuts and Jobs Act’s Impact on Cross-Border Transactions

Skadden, Arps, Slate, Meagher & Flom LLP on 1/27/2020

Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more

Understanding How to Compute a U.S. shareholder’s GILTI inclusion

Foodman CPAs & Advisors on 2/25/2019

The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Impact of US Tax Reform on Cross-Border Estate Planning

Skadden, Arps, Slate, Meagher & Flom LLP on 6/20/2018

The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more

The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends

McDermott Will & Schulte on 6/19/2018

The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on 1/3/2018

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Tax Act: Vote and Value

Alston & Bird on 1/3/2018

Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations. One of the new Tax Cuts and Jobs Act’s changes to Subpart F...more

Impacts on Foreign Operations That Affects Wholly-Owned and Majority Subsidiaries, And Potentially Minority Owned Stakes As Well

Orrick, Herrington & Sutcliffe LLP on 1/2/2018

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). The Bill was signed into law by President Trump on December 22. ...more

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