From Legislation to Implementation: Understanding Section 1202 Changes — Troutman Pepper Locke Podcast
AI Today in 5: August 12, 2025, The Creating Billionaires Episode
AI Today in 5: August 11, 2025, The ACHILLES Project Episode
Taxing Intelligence: AI's Role in Modern Tax Administration
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
Taking the Pulse, A Health Care and Life Sciences Video Podcast | Episode 242: Business Planning in Healthcare & Life Sciences with Jennifer McEwen of Maynard Nexsen
PODCAST: Williams Mullen's Benefits Companion - Employee Stock Ownership Plans (ESOPs) Explained
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
Essential Steps to Sell Your Business
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
Insights on Planned Giving From the BNY Annual Charitable Giving Report for 2024
Investing Charity and Foundation Assets in Turbulent Times With Jennifer Nelson
Podcast - Colaborar por contrato... sí funciona
Charitable Split Interest Trust Planning with Dale Schroeder and Anneke Niemira, Part Two
Charitable Split-Interest Trust Planning With Dale Schroeder and Anneke Niemira - Part One
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Choosing Your LDA Reporting Path for 2025
Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare
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
Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more
The Trump administration’s fluctuating tariffs pose major compliance risks for businesses operating in the U.S. Dive into the challenges they pose to businesses that rely on imported goods and services as Marina Gentile...more
On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more
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
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
For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections (REG-105479-18, the “Proposed Regulations”) addressing the treatment of previously taxed...more
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
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
DOING BUSINESS IN COLOMBIA - 1. Preliminary Considerations: In Colombia, a foreign company is able to act and do business by itself, for example, by contracting with local entities or investing foreign currencies....more
This note describes in outline the laws and taxes which currently apply to a foreign corporation establishing a business operation in the United Kingdom and the administrative requirements which need to be observed once the...more
In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more
You’re a foreign company looking to set up shop in the United States. You have weighed the pros and cons of expanding your business into the United States, c..onfirmed the compatibility of any products or services you offer...more
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more
Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more
In this episode, Mike Burke, AGG Corporate partner and leader of the Ireland & Northern Ireland practice, explores U.S. tax considerations for foreign businesses scaling to the U.S., including issues such as the branch...more
With more and more countries signing on to Pillar Two, “GILTI Conscience” hosts Nate Carden and David Farhat are joined by Vikram Chand, associate professor of law at the University of Lausanne, to discuss what this means for...more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more
A Canadian company adopting a deferred share unit plan (DSU plan) for its directors must consider U.S. tax implications for U.S. taxpayers. It is important to remember that U.S. citizens and U.S. residents for tax purposes...more
For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue. Section 962 allows an individual shareholder of a...more
The global economy is becoming increasingly integrated, and companies are routinely able to access markets throughout the world. For decades, the United States has maintained a robust economy and a strong market for imported...more
The Branch Profits Tax - The branch profits tax is imposed on foreign corporations engaged in a U.S. trade or business through a branch, rather than a subsidiary. The branch profits tax is imposed in addition to any tax on...more