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Proskauer Rose LLP

UK Tax Round Up - February 2025

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Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

DLA Piper

France - VAT: New French Administrative Guidelines - Regularisation of Incorrectly Invoiced VAT - Monthly Indirect Tax Alert –...

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The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more

McDermott Will & Schulte

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

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A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Freeman Law

International Tax Concepts: Dual-Status Taxpayers

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A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

Miller Nash LLP

A Non-U.S. Company’s Guide To Doing Business in the U.S.: Understanding Federal Taxes

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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

Freeman Law

Tax Treaty-Based Return Reporting Disclosures

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A taxpayer taking a treaty-based return position is generally required to disclose that position, unless an exception applies. A treaty-based return position is a tax reporting position, maintaining that a U.S. tax treaty...more

Freeman Law

The Tax Court in Brief - September 2021 #2

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Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...more

Gibney Anthony & Flaherty, LLP

Entering the US Market: Corporate Tax Considerations

As a manufacturer, selling your product(s) through an independent distributor is one way to enter the U.S. market without paying U.S. tax. The U.S. will seek to tax you if you have a business presence in the U.S...more

Freeman Law

The Tax Court in Brief - November 2020

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Proskauer - Tax Talks

Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships

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In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment...more

Nossaman LLP

Stay Ahead Of The Curve When Choosing Desired Tax Treatment

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A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more

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