Searching Content indexed under Income Tax by Orrick ordered by Published Date Descending.
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Attuazione degli incentivi fiscali all'investimento in PMI innovative
Le disposizioni si applicano in relazione agli investimenti effettuati nei periodi di imposta successivi a quello in corso al 31 dicembre 2016.
31 Jul 2019
New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations In Altera Case
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7...
United States
1 Jul 2019
HMRC Publishes UK Tax Guidance On Cryptocurrency For Individuals
On December 19, HMRC, the UK's counterpart to the US Treasury, published long-awaited (and arguably long overdue) guidance on the taxation of cryptocurrencies (which it refers to as "cryptoassets"), ...
14 Jun 2019
Proposed Regulations Favorably Affect Foreign Currency Hedging Transactions
United States shareholders of controlled foreign corporations ("CFCs") are required to include certain forms of passive income in their taxable income.
United States
14 Jun 2019
FDIC-Insured Institutions Report Net Income Of $59.1 Billion In Fourth Quarter 2018
The improvement in net income was led by higher net operating revenue and lower income tax expenses.
United States
13 Mar 2019
FHA Expands Pilot Program To Accelerate Financing Of Low-Income Housing Tax Credit Projects
On February 21, U.S. Housing and Urban Development (HUD) Secretary Ben Carson announced a significant expansion of a Federal Housing Administration (FHA)
United States
13 Mar 2019
Carried Interest Tax Regime In Italy (Art. 60 Of Law 96/2017)
The new tax regime aims at discounting the taxation of the excess profit attributed to investment managers or managers of target companies.
10 Aug 2017
The "Flat Tax" For Individuals Transferring Their Tax Residence To Italy
The option for the Flat Tax is communicated in the income tax return for the fiscal year in which the individuals transfer their residence to Italy or in the following year.
European Union
24 Apr 2017
La "Flat Tax" per i neo-residenti non domiciliati
Con la legge di bilancio 2017, il legislatore ha introdotto un regime opzionale di tassazione forfetaria (pari a € 100.000 annui) per le persone fisiche non residenti che intendono trasferire la residenza fiscale nel nostro Paese.
United States
18 Apr 2017
Midnight Regulations Provide Oil & Gas Mlps With Favorable Answers; New Administration Immediately Withdraws
Subsequent to the publication of our alert, on January 24, 2017, these regulations were published in the Federal Register and in that publication stated to have an effective date of January 19, 2017.
United States
7 Feb 2017
California Debt Limit Allocation Committee Releases Proposed Regulations
This client alert discusses some of the more significant changes that could affect issuers and borrowers in connection with awards of volume cap if the proposed regulations were adopted in their current form.
United States
27 Oct 2016
Tax Benefit From Leveraged Partnerships Shut Down By New IRS Regulations
The IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged partnerships.
United States
17 Oct 2016
Proposed Regulations Under §385 Classifying Interests In A Corporation
Orrick attorneys authored an article, titled "Proposed Regulations Under §385 Classifying Interests in a Corporation," addressing Section 385 regulations proposed by the Internal Revenue Service and the U.S. Treasury Department...
United States
1 Aug 2016
New FASB Tax Withholding Rules Give Companies (Particularly Multinationals) More Flexibility
As part of its Simplification Initiative, the FASB recently adopted Accounting Standards Update (ASU) 2016-09, Improvements to Employee Share-Based Payment Accounting...
United States
14 Jun 2016
IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments As Equity
On April 4, 2016, the IRS and U.S. Treasury Department issued proposed Treasury Regulations designed to curb the ability of large multinational companies to reduce their U.S. taxable income...
United States
5 May 2016
Patent Box - Ultimi Aggiornamenti Dall'Agenzia Delle Entrate
Il "Patent Box" consente alle società che svolgono attività di Ricerca & Sviluppo di optare, a partire dall'esercizio d'imposta 2015, per un regime di tassazione agevolata dei redditi generati dallo sfruttamento diretto o indiretto di risorse di proprietà intellettuale.
7 Apr 2016
Legislation Introduced To Extend Earned Income Tax Credit To Commonwealth Residents
This bill is related to a bill (H.R. 3552) previously introduced by Representative Pedro Pierluisi, which has been referred to the House Committee on Ways and Means.
Puerto Rico
10 Nov 2015
IRS Announces Intent To Tax Transfers To Partnerships
Generally, Code section 721(a) provides that a transfer of property to a partnership in exchange for an interest in the partnership will be accorded non-recognition treatment.
United States
18 Aug 2015
IRS Limits Correction Opportunities Under Section 409A
In Chief Counsel Advice 201518013 (May 1, 2015) (the "CCA"), the IRS addresses an executive retention bonus that originally vested after three years and was payable in equal instalments...
United States
19 May 2015
Practical Advice For Compliance With Recent Amendments To The Internal Revenue Code Section 162(m) Regulations
This clarification does not apply to stock options or SARs granted prior to the proposed regulations' effective date of June 24, 2011.
United States
27 Apr 2015
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