Related insights: Corporate Tax

US Treasury Issues Proposed Regulations on the Beneficial IRC Section 250 Corporate Tax Deduction Related to Export Sales of Property and Services

Mar 28 2019

US Treasury has now published detailed guidance on a significant US corporate tax rate benefit for any US company that conducts direct sales of property and/or services to foreign persons for foreign use. The tax rate benefit is achieved through a deduction of 37.5% from a direct foreign sales income base, before the 21% corporate tax rate is imposed. The deduction results in a 13% effective tax rate on qualifying direct foreign sales income.

US Tax Reform for Exporters that Both North Carolina Manufacturers and Triangle High Tech Businesses Can Love

Mar 22 2019

The 2017 Tax Cut and Jobs Act (“TCJA”) introduced a number of provisions that fundamentally change the way that the US taxes income from the foreign operations of US groups. One of the more favorable TCJA provisions provides for a significantly reduced rate of tax on income that US businesses earn directly from foreign sales.

New German VAT Legislation Impacts US Online Sellers and Marketplaces

Feb 18 2019

On January 1, 2019, German legislation took effect for enhanced value added tax (“VAT”) compliance obligations for marketplace providers facilitating the sale of physical goods to German consumers by sellers, wherever those sellers are located. This alert focuses on the impact of the German legislation on US sellers of physical goods online to German consumers.

European Anti-Tax Avoidance Directive Goes into Effect January 1, 2019

Feb 12 2019

On January 1, 2019, the EU Anti-Tax Avoidance Directive (“ATAD”) went into effect for all 28 Member States. How ATAD impacts specific group structures depends on the facts and circumstances of the particular structure and covered transactions.

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

Feb 06 2019

With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the “OECD”) has introduced greater direction for its BEPS mandate to introduce proposals to address the tax challenges of the “digitalization” of the economy.

Womble Bond Dickinson Recognized as a National Leader in 2019 Best Law Firm Rankings

Nov 01 2018

Womble Bond Dickinson is ranked as a top law firm in numerous national and market-specific practice areas in the 2019 Best Law Firm rankings from US News & World Report and The Best Lawyers in America.

Morris Ellison Speaks on Attorney-Client Privilege Issues in Ad Valorem Tax Appeals at American Property Tax Counsel Seminar

Nov 01 2018

Womble Bond Dickinson attorney Morris Ellison spoke at the 24th Annual American Property Tax Counsel Client Seminar in Scottsdale on protecting attorney-client privileges and work product in ad valorem property tax appeals.

U.S. and Foreign Businesses: You are Now “Virtually” Certain to Have Multistate Tax Obligations

Sep 04 2018

This article contains a brief introduction, a historical summary, a summary of immediate impacts, a legal/technical critique of Wayfair for attacking and/or legislatively overriding a Wayfair-type result, and a chart summarizing current state economic nexus sales tax approaches.

Businesses face unlimited fines for failure to prevent facilitation of tax evasion

Jan 03 2018

Andrew Barber, partner at Womble Bond Dickinson (UK) LLP, highlights the key elements of a new criminal offence in the UK designed to help to address the problem of tax evasion. The offence, and the underlying offences, should concern UK business, their senior management and employees. Richard Rainey, partner at Womble Bond Dickinson (US) LLP, explains similar provisions that apply in the US.

Womble Carlyle’s Mike Cashin Discusses Fourth Circuit COA Tax Decision with N.C. Lawyers Weekly

Jan 20 2017

The US Court of Appeals for the Fourth Circuit recently upheld an IRS decision to reject a claimed $118 million salary and wage deduction by QinetiQ US Holdings Inc. Womble Carlyle attorney Mike Cashin discussed the ruling, and its implications, with North Carolina Lawyers Weekly.

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