Searching Content indexed under Corporate Tax by Kramer Levin Naftalis & Frankel LLP ordered by Published Date Descending.
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Tax Reform Act Changes To CFC Attribution Rules
The recently enacted tax reform act significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct dividends received from...
United States
5 Apr 2018
REITs And Their Shareholders Stand To Gain Under New Tax Law
In their article "REITs and Their Shareholders Stand to Gain Under New Tax Law," which appeared in the March 2, 2018, issue of Commercial Observer, Tax partner Barry Herzog and associate Rita Celebrezze D'Souza...
United States
14 Mar 2018
SEC Releases Guidance On Near-Term Disclosure Regarding Effects Of New Tax Law
The tax reform signed into law by President Trump on Dec. 22 (the Tax Act) presents public companies with several accounting and disclosure challenges.
United States
3 Jan 2018
Tax Reform
On Dec. 22, 2017, President Trump signed into law tax reform legislation ("the Act") that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal Revenue Code of 1986, as amended ("the Code"), which likely will significantly affect many of our clients:
United States
3 Jan 2018
Tax Reform Bills Seek Largest Restructuring Of Tax Code In More Than A Generation
On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act.
United States
4 Dec 2017
New Treasury Regulations Make Inversions More Difficult And Alter The Treatment Of Debt Instruments Between Related Companies
Corporate inversions have been at the forefront of discussions regarding international tax reform.
United States
16 May 2016
IRS Reverses Itself On Treatment Of 'Bad Boy Guarantees'
In February 2016, the IRS released an internal memorandum concluding that typical 'bad boy guaranties' provided by a partner for partnership debt should be treated as a recourse liability of the guarantor...
United States
25 Apr 2016
Holdings Are Targeted By The French Tax Administration
It should thus be useful to implement various measures to strengthen the lead position of your holding.
24 Mar 2016
Tax Alert - Les Holdings Dans Le Viseur Du FISC
L'article 29 de la Loi de finances rectificative pour 2015, passé relativement inaperçu, modifie pourtant sèvèrement les articles 119 ter et 145 du Code général des impôts.
16 Mar 2016
New IRS Ruling Guidance May Cast Doubt On Some Tax-Free Spinoffs
On Sept. 14, the IRS released new guidance (Notice and Revenue Procedure) limiting the types of spinoffs eligible for private letter rulings, signaling mounting IRS concerns regarding transactions involving companies with significant passive assets.
United States
2 Oct 2015
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