Practice/Industry Group Overview
Jones Day’s Tax Practice assists clients in responding to the challenges of the current environment by emphasizing the development of creative, practical solutions to tax problems.
The focus of the Tax Practice reflects the changing business environment in which we live. The tax law is becoming more dispute-oriented, more international in scope and, despite efforts to the contrary, more complicated and subject to frequent revision. The client service challenges created by complexity and change are addressed in part by the identification and development of Firm leaders in key areas of practice. These lawyers combine extensive experience with an understanding of the latest developments in their field, and many have been recognized as among the world’s outstanding tax practitioners. The knowledge and experience of each tax lawyer is made available Firmwide through a long tradition of close collaboration and cooperation across offices and practices.
Articles Authored by Lawyers at this office:
New Section 871(m) Regulations—A New "Sin"-less Approach
Ilene Katinka Froom,Kent L. Killelea,Todd Wallace, December 13, 2013
On December 5, the U.S. Treasury reproposed the Section 871(m) regulations with a new standard for determining which dividend-related payments on equity derivative transactions with non-U.S. counterparties are subject to U.S. withholding. The new proposed regulations would apply a more objective...
Mexico's Congress Passes Tax Reform
Javier A. Cortes,Rodrigo Gómez,Joseph A. Goldman,Rodrigo Rangel Hassey,Matthew A. Martel, November 07, 2013
The two houses of the Mexican Congress (the Chamber of Deputies and the Senate) last week passed a tax reform measure which now awaits President Enrique Peña Nieto's signature. The legislation is significantly different than the President's controversial tax overhaul proposal forwarded to...
Mexican Tax Reform Update
Javier A. Cortes,Rodrigo Gómez,Joseph A. Goldman,Luis Ignacio Martel, October 23, 2013
On October 17, the Mexican Congress modified the proposed tax reform that was prepared by the executive branch (led by President Enrique Peña Nieto) and forwarded to Congress on September 8. The executive branch's tax proposal had met with opposition from conservatives in Congress and many...
Internal Revenue Code Section 336(e) Elections: Basic Overview
Patrick J. Browne,Lester W. Droller,Andrew M. Eisenberg, September 19, 2013
The U.S. Treasury Department recently issued final regulations allowing certain taxpayers to make a special election to treat a disposition of domestic company stock as a disposition of that company's assets for U.S. federal income tax purposes. Depending on the facts of each particular disposition...
CRD IV Update: Some Good (Tax) News for the UK's Banking Sector
John Ahern,Amrit Dehal,Catherine Richardson, September 11, 2013
The Capital Requirements Directive IV and the Capital Requirements Regulation (collectively "CRD IV") implement, within the European Union, the Basel III reforms and provide for the prudential rules for banks, building societies and investment firms. Although CRD IV entered into force on...
Six-Month Extension of FATCA Deadlines—Another Joy of Summer
Kent L. Killelea,Colleen E. Laduzinski,Todd Wallace, July 18, 2013
The IRS announced on Friday, July 12, in Notice 2013-43 (the "Notice") that the earliest deadlines under the Foreign Account Tax Compliance Act ("FATCA") have been extended by six months. FATCA withholding will now not begin until July 1, 2014. Thus, foreign financial...
Tax Issues Regarding Internationally Mobile Employees in Europe
, May 31, 2013
For businesses that employ internationally mobile employees (“IMEs”), or are considering doing so, and who provide (or who may provide) equity incentive compensation (for example, stock options and restricted stock units (“RSUs”)) to their IMEs, there are many tax issues...
New Tax Treaties between Mexico and Hong Kong and Qatar
Rodrigo Gómez,Luis Ignacio Martel,Luis Rodrigo Salinas, May 06, 2013
In March 2013, two new income tax treaties signed by Mexico-with Hong Kong and with Qatar-were published in the Mexican Official Gazette. With these new tax treaties, Mexico will have a tax treaty network comprising 54 countries. Both tax treaties will become effective as of January 1, 2014.
The FATCA Protocol: To Adhere or Not To Adhere?
Ilene Katinka Froom,Kent L. Killelea,Edward J. Nalbantian,Todd Wallace, April 15, 2013
On August 15, 2012, the International Swaps and Derivatives Association ("ISDA") released a new Protocol relating to the effect on ISDA derivatives of taxes levied by the United States under the Foreign Account Tax Compliance Act ("FATCA"). FATCA was enacted in 2010 as part of...