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Corporate Tax 2025 — USA: Law & Practice

Devon Bodoh — Mon, 07 Apr 2025 17:29:51 +0000

The Corporate Tax 2025 guide provides the latest legal information on types of business entities, special incentives, consolidated tax grouping, individual and corporate tax rates, withholding taxes, tax treaties, transfer pricing, anti-avoidance, audit cycles, and base erosion and profit shifting. Continue Reading.

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The Tariff Sheriff: The Tug-of-Trade-War

Devon Bodoh — Tue, 04 Feb 2025 13:51:50 +0000

On February 1, 2025, President Trump issued three Executive Orders directing the United States to impose new tariffs on imports from Mexico, Canada and China, each set to take effect on February 4, 2025. On February 3, 2025, however, Mexico and Canada each separately agreed to a deal to delay the tariffs for a month

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Now You See Me, Now You Don’t OECD ME: President Trump Signals Significant Changes in Global Tax Policy

Devon Bodoh — Mon, 27 Jan 2025 15:15:02 +0000

On January 20, 2025, President Trump signed two Executive Orders signaling a marked departure from Former President Biden’s Administration on global tax and trade policy. The first Executive Order (the “Global Tax Deal EO”) takes aim at the Organization for Economic Cooperation and Development (“OECD”) two pillar project and essentially nullifies the U.S.’s agreement to

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Be Careful Out There: IRS Issues Guidance on Tax Planning Transaction with Broad Application

Devon Bodoh — Fri, 10 Jan 2025 19:31:56 +0000

On January 3, 2025, the Internal Revenue Service (“IRS”) issued a legal advice memorandum (from the Office of Chief Counsel) – CCA 202501008 (the “CCA”) dealing with a tax planning transaction aggressively applying an anti-avoidance rule. Specifically, the CCA concerned the application of the anti-abuse provision of Section 269 of the Internal Revenue Code (the

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IRS Issues Important Cross Border Proposed Regulations

Devon Bodoh — Thu, 05 Dec 2024 15:11:40 +0000

On November 29, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) announced proposed regulations (the “Proposed Regulations”) (REG-105479-18) regarding previously taxed earnings and profits (“PTEP”) of foreign corporations and related basis adjustments. The IRS requests public comments on the proposed rulemaking, which aims to clarify the tax consequences of PTEP under Sections

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2024 Election Observations: The Future of Tax Policy under A Second Trump Administration

Devon Bodoh — Wed, 13 Nov 2024 15:45:08 +0000

On November 5, former President Donald J. Trump was elected to serve as the 47th President of the United States. As of today, it is now certain that Republicans will be in control of both the Senate and the U.S. House of Representatives. Unified control of Congress significantly enhances the prospects that many of President Trump’s tax proposals become law. Similar to the approach taken in respect of the Tax Cuts and Jobs Act of 2017 and, more recently, the Inflation Reduction Act of 2022, unified Republican control should enable the use of the “budget reconciliation” procedures that would allow for passage of new tax legislation relying solely on a simple majority of Republican votes. Although budget reconciliation provides fast-track procedures to avoid some procedural hurdles that might otherwise stall legislation, there are limits on when and how it can be used.

TREASURY AND IRS ISSUE FINAL RULES RELATING TO REPATRIATION OF IP

Devon Bodoh — Thu, 10 Oct 2024 15:50:38 +0000

On October 9, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”), which, in certain cases, terminate the continued application of Section 367(d) of the Internal Revenue Code (the “Code”) from a previous transfer of intangible property to a foreign corporation when the intangible property is repatriated to

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Treasury and IRS Issue Long Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

Joseph Pari — Mon, 16 Sep 2024 13:38:23 +0000

On September 12, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG 112129-23, RIN 1545-BQ84) (the “Proposed Regulations”) providing much needed guidance on the application of the corporate alternative minimum tax (“CAMT”). In addition to the Proposed Regulations, Treasury and the IRS also issued Notice 2024-66, which waives the

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Easy as ABC – IRS Issues Final Rules Aimed at Stymieing Killer Bs

Devon Bodoh — Thu, 18 Jul 2024 15:06:40 +0000

On July 17, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations under Section 367(b) of the Internal Revenue Code (the “Code”) that provide guidance applicable to: the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to those reorganizations; and the treatment of certain subsequent inbound nonrecognition transactions following those reorganizations and certain other tax-free transactions (the “Final Regulations”). The Final Regulations adopt, without significant modification, the proposed regulations (published in the Federal Register on October 6, 2023) (the “Proposed Regulations”).

Final Regulations: Guidance on Reporting and Payment of Excise Tax

Devon Bodoh — Tue, 02 Jul 2024 15:52:31 +0000

On June 28, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (T.D. 10002) (the “Final Regulations”) that provide guidance applicable to the reporting and payment of the excise tax under section 4501 of the Internal Revenue Code of 1986, as amended (the “Code”), on repurchases of

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