Tax Cuts and Jobs Act, Controlled Foreign Corporations, Foreign Investment

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

Venable LLP on 6/5/2025

As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

Supreme Court to Decide: No Realization Means No Moore Income Tax?

Rivkin Radler LLP on 10/13/2023

Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on 7/11/2023

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

The Section 965 Transition Tax And IRS Audits

Freeman Law on 9/14/2021

Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more

Blog: Primer - U.S. Tax Considerations for Venture Capital Funds

Cooley LLP on 8/6/2020

We are frequently asked by our fund manager clients about what tax issues they should consider when forming a new venture capital fund or investing in portfolio companies. In this post, we outline a few key considerations for...more

New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs

Proskauer - Tax Talks on 9/24/2018

On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation deemed to have been received by a registered investment company (a “RIC”) under...more

Expect Focus - International - March 2018

Carlton Fields on 4/11/2018

Trends Against BITS and Investor State Dispute Resolution - In my first Expect Focus International article (http://bit.ly/2G9Demu), I suggested that investors doing business outside the United States should do so in...more

U.S. Tax Reform Has A Profound Impact On Inbound Investment

Orrick, Herrington & Sutcliffe LLP on 3/7/2018

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Tax Cuts and Jobs Act › Controlled Foreign Corporations › Foreign Investment

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