Tax Law Still Leaves Room For Companies To Write Off Settlement Agreements

In two recent Bloomberg Law articles, Kat Gregor comments on rules governing deductibility of payments enacted to governments as part of 2017 tax reform, including deporting requirements under section 6050X of the Code. The purpose of these new guidelines is to “boost transparency in corporate settlements and make it easier for the IRS to keep track of how much of a settlement payment a company is required to pay off.” Kat specifically notes that the Code’s […]

By |August 8th, 2018|

Australia Announces Changes To Tax Incentive For Research And Development (R&D)

Proposed changes to R&D tax incentives regime in Australia will reward R&D intensity. Companies operating in Australia can benefit significantly if they know how to tap into this opportunity.

An overhaul of the R&D tax incentive legislation in Australia has been proposed which will have the effect of rewarding businesses with greater R&D intensity i.e. higher R&D spend as a proportion of total spend. The changes, once implemented, will apply to financial years commencing on […]

By |August 8th, 2018|

U.S. Tax Reform: The End Of The LLC?

In this article, the authors consider the effect the U.S. Tax Cuts and Jobs Act may have on Canada regarding both U.S. inbound and outbound investments.

According to the Office of the United States Trade Representative, U.S. goods and services trade with Canada totaled an estimated $673.9 billion in 2017. In 2016 U.S. foreign direct investment into Canada was $363.9 billion, and Canada’s foreign direct investment in the United States was $371.5 billion. With bilateral […]

By |August 6th, 2018|