News & Analysis as of

Tax Planning Foreign Investment Income Taxes

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

Kilpatrick on

Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

Allen Barron, Inc. on

Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Allen Barron, Inc.

International Business Dealings Require Integrated Legal, Tax and Accounting Support

Allen Barron, Inc. on

Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

Establishing a Subsidiary in the U.S. - A Nordic Perspective

This note only addresses subsidiaries of Nordic companies. Branch offices are rarely attractive for foreign companies because they result in direct exposure for the foreign company to liability in the U.S. and jurisdiction by...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Navigating Permanent Establishment Risks in Cross-Border Employment

As businesses continue to expand their operations across borders—by engaging contractors, hiring employees, or initiating other revenue-generating activities overseas—understanding permanent establishment risks becomes...more

Foley & Lardner LLP

Mexican Government Announces Incentives in Support of Nearshoring

Foley & Lardner LLP on

On January 21, 2025, the Decree granting tax incentives in support of the national strategy known as “Plan Mexico,” to encourage new investments that promote dual training programs and innovation (Nearshoring Decree) was...more

Mayer Brown

Prix de transfert : la détermination du taux d'intérêt de référence concernant les avances intragroupe

Mayer Brown on

Dans une décision qui sera mentionnée aux tables du Recueil Lebon, le Conseil d'Etat apporte des précisions relatives au régime de la charge de la preuve en matière de prix de transfert en présence d'avances consenties sans...more

Davies Ward Phillips & Vineberg LLP

Selected US Tax Developments

Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more

Allen Barron, Inc.

The Potential Tax Impact of Foreign Investments

Allen Barron, Inc. on

A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

Strafford on

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

Foodman CPAs & Advisors

Impuestos 2023: Lo Mejor Es Prepararse Ahora

La planificación fiscal le aplica a todos. El 1/22/24, el IRS le recordó a todos los contribuyentes que comenzaran a prepararse para presentar su declaración de impuestos federales sobre la renta. Planificar con anticipación...more

Foodman CPAs & Advisors

2023 Taxes: Best To Get Ready Now

Tax planning applies to everyone. On 1/22/24, IRS reminded all taxpayers to start getting ready to file their federal income tax return. Planning ahead can help taxpayers file an accurate return and avoid delays that can slow...more

Davies Ward Phillips & Vineberg LLP

Revised U.S. Tax Proposals Will Affect Foreign Investment

The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...more

McDermott Will & Schulte

Policy Outlook: How The 2020 Election Outcomes Will Impact Your Business - Health Policy

In this session, health law policy authorities discussed changes likely in 2021 in a Biden Administration and how these changes will impact business objectives and strategies for health industry stakeholders...more

McDermott Will & Schulte

[Webinar] Policy Outlook: How The 2020 Election Outcomes Will Impact Your Business - November 5th, 12:00 pm - 2:15 pm EST

McDermott Will & Schulte on

Are you prepared for the critical impacts of the US election outcome to you and your business in 2021 and beyond? Join McDermott’s lawyers and our policy and lobbying team for perspective on the effects of administration...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Cooley LLP

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

Cooley LLP on

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

Proskauer Rose LLP

UK Tax Round Up - February 2020

Proskauer Rose LLP on

UK General Tax Developments - HMRC updates to the private sector IR35 rules - On 7 February 2020, HMRC confirmed that the new private sector IR35 rules will only apply to payments made for services provided on or...more

McDermott Will & Schulte

[Event] The US-Chile Tax Treaty And Its Imminent Impact On Taxpayers – December 2019 Approval Expected - September 25th, Miami, FL

After nearly a decade of being put on hold, several members of the Senate Foreign Relations Committee have recently indicated that the first US-Chile Income Tax Treaty is expected to be approved by the end of the year. The...more

Troutman Pepper Locke

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

Troutman Pepper Locke on

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

Orrick, Herrington & Sutcliffe LLP

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

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

Bracewell LLP

Bracewell Tax Report: February 2018 #2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

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