As a result of the significant reduction of U.S. corporate income tax rates pursuant to the tax reform of the TCJA enacted on December 22, 2017, the Unites States now has a lower corporate tax rate than many of its trading partners, meaning that, in many instances, the profits of foreign owned or controlled-U.S. subsidiaries shall be taxed more favorably than the profits of their foreign parent companies or affiliates in their home jurisdictions. That creates an incentive for foreign companies to channel more profits through their U.S. subsidiaries, in order to benefit from lower U.S. income taxation compared to that applicable in the parent company’s home country. Read more
Tag Archive for Italy tax
U.S. Impact Of Federal Tax Reform From Italy’s Perspective: Renewed Attention On Italy’s Anti Inversion Rules
This is the fourth of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),
Individual taxation – Modification of black-list criteria for CFC purposes: taxation of profits accrued and distributed in different fiscal periods and under different rules Read more
The Italian 2018 Budget Law, approved by the Parliament on 23 December 2017 and turned into Law No. 205 of 27 December 2017, has introduced a package of tax reforms for corporations and individuals.
This is the first of a series of posts on the major developments introduced by Law No. 205. In each post is provided a general overview of a specific tax reform.