The One Big Beautiful Bill Act is a massive bill that overhauls much of the U.S. tax system. Our Federal & International Tax and State & Local Tax teams cover the Act’s key tax provisions for individuals and businesses....more
With the release of its FY 2022 revenue proposals, the Biden Administration explains and refines some of the tax priorities raised on the campaign trail. Our International Tax Group reads the tea leaves to find the...more
Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more