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1
Rare Supremacy Clause Tax Win For P.L. 86-272 Company
In a rare challenge involving the US Constitution's Supremacy Clause, Mayer Brown lawyers successfully argued that New Jersey's Corporate Business Tax alternative minimum assessment has been unconstitutional since 2006.
United States
12 Jul 2019
2
Capital Markets Tax Quarterly 23 January 2019
As CMTQ hits the newsstands, a substantial part of the US government is on hold because of the failure to pass various appropriations bills for the 2019 fiscal year.
United States
28 Jan 2019
3
Window Of Opportunity: The IRS Issues Initial Guidance On Qualified Opportunity Zone Rules
It is extremely rare that a section of the US Internal Revenue Code of 1986, as amended (the "Code") ...
United States
29 Oct 2018
4
Capital Markets Tax Quarterly
Welcome to Mayer Brown's Capital Markets Tax Quarterly (CMTQ). This is a new publication for Mayer Brown's Tax practice, so let us explain what we're about.
United States
23 Oct 2018
5
A New Jersey Jughandle—New Legislation Brings Combined Reporting, A 95% DRD And Market-Based Sourcing To The Garden State
Two weeks ago, we provided a Legal Update on the then-current version of the New Jersey budget legislation.
United States
11 Jul 2018
6
Infocast's 2018 Solar Power Finance & Investment Summit Soundbites
Below are soundbites from panelists at Infocast's Solar Power Finance & Investment Summit from March 19th to 22nd in Carlsbad, CA.
United States
26 Apr 2018
7
What Is The Impact Of Tax Reform On US Wind Tax Equity Deals?
A Word About Wind has published our article What Is the Impact of Tax Reform on US Wind Tax Equity Deals?
United States
19 Jan 2018
8
Senate's Tax Bill's Impact On The Tax Equity Market: Five Differences From The House Bill
Below we describe the five differences from the House bill that are of greatest significance to the renewable energy tax equity market.
United States
17 Jan 2018
9
House Passes Tax Reform & The Impact Of Tax Reform On The Renewable Energy Market
Today, the House voted 227 to 303 in favor of the tax reform bill agreed to by the conference committee. No Democrats voted for the House bill, and 12 Republicans from high tax states voted against it.
United States
16 Jan 2018
10
Treasury And The IRS Introduce Significant Changes In The Final Section 385 Regulations On Intercompany Debt
This legal update provides a brief summary of the most significant changes included in the Final Regulations.
United States
17 Oct 2016
11
New Republican Tax Proposal: The Key To Unlocking US Tax Reform In 2017?
On June 24, 2016, House Republicans, led by Speaker Paul Ryan and Ways & Means Committee Chairman Kevin Brady, released an outline of an aggressive tax reform proposal.
United States
6 Jul 2016
12
Examining The Proposed U.S. Country-By-Country Reporting Regs
Following the OECD recommendation under the BEPS project, in December 2015 the U.S. Treasury issued proposed regulations on country-by-country reporting.
United States
5 May 2016
13
Treasury's New Anti-Inversion Regulations: Do They Go Too Far?
On April 4, the US Treasury and the IRS issued extensive proposed and temporary regulations described as curbing inversions and addressing earnings stripping.
United States
11 Apr 2016
14
The Difficulty Of GLAM 2015-002's Five-Step Approach
With the promulgation of the check-the-box regulations and the proliferation of branches (for U.S. tax purposes), a number of U.S. international tax provisions gained significantly in importance.
United States
23 Sep 2015
15
International Partnerships, Joint Ventures And Hybrids - The New Regulations On Qualifying Income For Master Limited Partnerships
A Master Limited Partnership or MLP is an attractive business entity because it is treated as a partnership for federal income tax purposes even though the ownership interests in the MLP are publicly traded.
United States
22 Sep 2015
16
US IRS Issues Proposed Regulations On Master Limited Partnership Income
The US Internal Revenue Service (IRS) has published proposed regulations clarifying which activities generate "qualifying income" for a Master Limited Partnership (MLP).
United States
8 May 2015
17
Proposed US Treasury Regulations Attempt to Distinguish "Active" Insurance Companies from Hedge Funds
Offshore insurance companies can provide substantial tax benefits to their owner-insureds through current deductions for the insurance premium and, if properly structured, deferral on reserve investments.
United States
28 Apr 2015
18
Why Senator Leahy’s Proposal To Bar Businesses From Deducting Punitive Awards From Taxable Income Is A Bad Idea
In mid-January, Senator Patrick Leahy (Dem. Vt.) proposed—again—legislation that would prevent businesses from deducting from taxable income any punitive damages they have paid during the relevant tax year.
United States
12 Feb 2015
19
Three Things US Audit Committee Members Should Consider In 2015
Audit Committees are facing increased demands from many quarters heading into 2015.
United States
26 Jan 2015
20
Fractional Taxation: IRS Releases Technical Advice Addressing The 10% Securities Rule Applicable To Foreign Bank Branches
Detailed special rules apply to determine whether, and the extent to which, income from a security is considered attributable to the conduct of a banking, financing, or similar business in the United States by a non-US bank.
United States
1 Jul 2013
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