Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On May 12, 2025, the House Committee on Ways and Means (WMC) released a draft of the tax provisions of the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill” Act (OBBB), and on May 14,...more
5/21/2025
/ Foreign Corporations ,
International Tax Issues ,
New Legislation ,
OECD ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Rates ,
Tax Reform ,
U.S. House ,
Ways and Means Committee
Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is...more
9/1/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Profits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
OECD ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform