On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more
8/26/2025
/ Cross-Border Transactions ,
Distribution Rules ,
Domicile ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Publicly-Traded Companies ,
Reorganizations ,
Stocks ,
Tax Planning ,
Tax Relief
On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more