Searching Content indexed under Corporate Tax by Ruchelman PLLC ordered by Published Date Descending.
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The Devil In The Detail: Choosing A U.S. Business Structure Post-Tax Reform
This article looks into some important tax considerations for an individual planning to start a U.S. business.
United States
8 Jul 2019
New Jersey Provides G.I.L.T.I. Guidance
Federal tax law has introduced a new type of gross income. The provisions applicable to Global Intangible Low Tax Income ("G.I.L.T.I.") are designed to stop U.S.
United States
20 May 2019
Holding Companies Of Europe – Tax Planning For European Expansion In A Changing Landscape
Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes ...
United States
15 Jan 2019
A Deep Dive Into G.I.L.T.I. Guidance
The 2017 Tax Cuts and Jobs Act ("T.C.J.A.") introduced a new anti-abuse tax regime applicable to controlled foreign corporations ("C.F.C.'s").
United States
12 Dec 2018
Happy Ending For The Home Of The Happy Meal – No Illegal State Aid To McDonald's
On September 19, 2018, the European Commission issued a decision that nontaxation of certain McDonald's profits in Luxembourg was not illegal State Aid.
18 Oct 2018
Hybrid Mismatches: Where U.S. Tax Law And A.T.A.D. Meet
This article focuses on the interaction between certain hybrid mismatch provisions of A.T.A.D. 2 and certain provisions of U.S. tax law.
United States
2 Oct 2018
Tax Basics Of Intellectual Property
Like most assets developed, used, and sold in business, intellectual property (IP) is subject to important tax considerations.
United States
2 Sep 2018
Outbound Acquisitions: Holding Companies Of Europe – A Guide For Tax Planning, Or A Road Map For Difficulty?
When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.
United States
30 Aug 2018
Updates And Other Tidbits
In IR-2018-131, issued on June 4, 2018, the I.R.S. announced that it will waive certain late-payment penalties relating to the Code ง965 transition tax ...
United States
2 Jul 2018
Corporate Matters: Profits Interest Basics
In previous articles we have discussed the relative flexibility of limited liability companies ("L.L.C.'s"), which are generally taxed as partnerships ...
United States
29 Jun 2018
Code ง962 Election Offers Benefits Under U.S. Tax Reform
Under Code ง962, an individual U.S. Shareholder may elect to be treated as a domestic C-corporation for the purpose of computing income tax on its share of Subpart F Income.
United States
16 May 2018
I.R.S. Offers Additional Guidance On Code ง965 Transition Tax
On the way toward a dividends received deduction for certain dividends paid by foreign subsidiaries, Congress enacted a one-shot income inclusion of all post-1986 earnings...
United States
16 Apr 2018
Changes To C.F.C. Rules – More C.F.C.'s, More U.S. Shareholders, More Attribution, More Compliance
One of the principal revisions to U.S. tax law made by the Tax Cuts and Jobs Act ("T.C.J.A.") was a series of changes to the definition of the term Controlled Foreign Corporation ("C.F.C.").
United States
12 Apr 2018
A New Opportunity For Nonresident Aliens – Ownership In An S-Corp
Changes to U.S. tax law brought about by the 2017 Tax Cuts and Job Act ("T.C.J.A.") have affected many longstanding tax planning tools.
United States
13 Mar 2018
Non-Corporate Taxation: Individuals & Partnerships Face Highs & Lows Under The T.C.J.A.
The Tax Cuts and Jobs Act ("T.C.J.A.") brought many changes for non-corporate taxation, changing tax rates and repealing many popular deductions.
United States
12 Mar 2018
B.E.A.T.-Ing Base Erosion: U.S. Subjects Large Corporations To Anti-Abuse Tax
The Tax Cuts and Jobs Act ("T.C.J.A.") introduced Code ง59A, which imposes a new Base Erosion and Anti-Abuse Tax ("B.E.A.T.") on large corporations that significantly reduce their U.S. tax liability ...
United States
9 Mar 2018
Qualified Business Income – Are You Eligible For A 20% Deduction?
The Tax Cuts and Jobs Act ("T.C.J.A."), signed into law on December 22, 2017, contained several major changes with respect to individuals and entities.
United States
8 Mar 2018
Individual, Corporate, And Trust News From France
As explained in the January 2017 edition of Insights, the end of the year in France is always marked by a fiscal legislative process to amend the current year's finance law ...
6 Feb 2018
Modifications To The Foreign Tax Credit System Under The Tax Cuts And Jobs Act
One of the principal revisions to U.S. tax law made by the TCJA involves the way U.S. tax law avoids double taxation when a foreign subsidiary distributes a dividend to a U.S. corporation...
United States
2 Feb 2018
Impact Of The Tax Cuts And Job Act On U.S. Investors In Foreign Corporations
This article addresses provisions of the Tax Cuts and Jobs Act of 2017 that affect certain U.S. investors in foreign corporations on a go-forward basis and a one-year transition period for the 2017 taxable year.
United States
2 Feb 2018
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