This bulletin follows our previous update on evolving U.S. tax reform, which highlighted the competing House and Senate proposals, particularly the introduction and scope of proposed Section 899 targeting "unfair foreign...more
7/21/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
EBITDA ,
Estate Tax ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
International Tax Issues ,
New Legislation ,
One Big Beautiful Bill Act ,
Opportunity Zones ,
Qualified Business Income ,
SALT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Legislation ,
Tax Planning ,
Tax Reform
As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more
6/23/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Digital Services ,
Diverted Profits Tax ,
FIRPTA ,
Foreign Investment ,
Foreign Tax ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Investors ,
Multinationals ,
Proposed Legislation ,
Retaliatory Tariffs ,
Senate Finance Committee ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more
As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us.
Review of U.S. Tax Developments in 2022-
In 2022 we...more
With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically,...more
The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more
8/18/2022
/ Biden Administration ,
Carried Interest ,
Climate Change ,
Corporate Taxes ,
Enforcement ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
IRS ,
New Legislation ,
Portfolio Companies ,
Share Buybacks ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Wealth Tax
Review of U.S. Tax Developments in 2021-
Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
3/4/2022
/ Anti-Injunction Act ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
BEPS ,
Capital Gains ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Infrastructure ,
IRS ,
Joe Biden ,
Like Kind Exchanges ,
Net Investment Income ,
OECD ,
PFIC ,
Popular ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Treaty ,
U.S. Treasury