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Searching Content indexed under Corporate/Commercial Law by Ruchelman PLLC ordered by Published Date Descending.
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1
Grecian Magnesite Put To Bed: Tax Court Ruling Affirmed On Appeal
Recently, the Court of Appeals for the D.C. Circuit affirmed the 2017 Tax Court ruling in the matter of Grecian Magnesite Mining v. Commr., which held that a foreign corporation was not liable for U.S. tax on the gain ...
United States
11 Jul 2019
2
United States
10 Jul 2019
3
Corporate Matters: Delaware Law Allows L.L.C. Divisions
In 2018, Delaware amended its limited liability company act to add Section 18-217, which enables an L.L.C. to divide into two or more newly formed L.L.C.'s, with the dividing company either continuing or terminating its existence.
United States
20 Jun 2019
4
Peeling The Onion To Allocate Subpart F Income – This Will Make You Cry!
There has been a wealth of conversation addressing the amendment to the definition of a "U.S. Shareholder" in the context of a controlled foreign corporation introduced by the 2017 Tax Cuts and Jobs Act.
United States
18 Jun 2019
5
It's Time For Cayman Shell Entities To Come Out Of Their Shells And Show Economic Substance
In response to the O.E.C.D.'s B.E.P.S. recommendations and the conclusions and concerns identified by the E.U. Code of Conduct Group of Business Taxation,
Cayman Islands
20 May 2019
6
The I.R.S. Approach To Dependent Agent Status
When foreign corporations have certain activities in the U.S., the question often arises as to whether a taxable presence exists in the U.S. for Federal income tax purposes.
United States
11 Apr 2019
7
Proposed Amendments To F.A.T.C.A. Suggest Reducing Or Deferring Withholding
On December 13, 2018, the I.R.S. issued proposed regulations under Code งง1471 through 1474 (F.A.T.C.A provisions) as well as under Code งง1441 and 1461 (withholding on non-U.S.
United States
11 Mar 2019
8
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
9
C-Corps Exempt From Full Scope Of Foreign Income Inclusion
On October 31, 2018, the I.R.S. proposed regulations affecting controlled foreign corporations ("C.F.C.'s") and U.S. corporations that are considered to be U.S. Shareholders ...
United States
12 Dec 2018
10
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
11
Transition Tax – Proposed Regulations Are Here
The Treasury Department and the I.R.S. recently published proposed regulations on Code ง965 (the "Proposed Regulations").
United States
12 Nov 2018
12
Qualified Business Income – Are You Eligible For A 20% Deduction? Part II: Additional Guidance
On August 8, 2018, the I.R.S. issued much-awaited proposed regulations under new Code ง199A, which was added by the 2017 Tax Cuts and Jobs Act. The provision was initially discussed in detail in our February 2018 edition.
United States
12 Nov 2018
13
D.O.J. Resorts To Undercover Operations To Secure First Conviction Under F. A.T.C.A.
Mr. Baron was extradited to the U.S. from Hungary in July.
United States
18 Oct 2018
14
F.A.T.C.A. – Where Do We Stand Today?
A participating F.F.I. files Form 8966, F.A.T.C.A. Report, annually with the I.R.S. The
United States
18 Oct 2018
15
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.
Worldwide
18 Oct 2018
16
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
17
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
18
U.K. Requirement To Correct
The "Requirement to Correct" ("R.T.C.") rules became law when the Finance (No. 2) Act 2017 received Royal Assent on November 16, 2017.
UK
7 Aug 2018
19
I.R.S. Proposed Regulations Provide Clarity On Code ง965 Transition Tax
On August 1, 2018, the I.R.S. issued 145 pages of proposed regulations (REG-104226-18) relating to the Code ง965 Transition Tax applicable to the 2017 taxable year of U.S. Shareholders...
United States
3 Aug 2018
20
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
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