Each of these items will help ensure that a U.S.-based joint venture (JV)—especially one in a regulated industry with cross-border aspects—is set up and operated on solid legal, compliance, and tax footing. By diligently...more
On July 3, 2025, the U.S. Congress passed H.R. 1, “An Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14” (the “Act”). The Act was signed into law on July 4, 2025.
The House of Representatives passed...more
Globally, market volatility has eroded confidence and subdued M&A activity. A “wait and see” approach is the prevailing sentiment for many market participants; it is difficult to convince boards to advance deals while...more
How are dealmakers responding to an uncertain and volatile macro environment? Our latest M&A Insights report offers a global perspective on the forces shaping M&A activity, from the rising interest in the European defense...more
On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more
5/29/2025
/ Budget Reconciliation ,
Business Taxes ,
Deadlines ,
Estate Tax ,
Federal Budget ,
FIRPTA ,
Gift Tax ,
GILTI tax ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Local Taxes ,
Net Investment Income ,
Proposed Legislation ,
REIT ,
SALT ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Legislation ,
Tax Liability ,
Tax Rates ,
Tax Reform
On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”).
The House Draft Bill is primarily...more
5/13/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Legislative Agendas ,
Proposed Legislation ,
Regulatory Agenda ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Ways and Means Committee
Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more
On November 29, 2024, the U.S. Treasury Department and IRS released long-awaited proposed regulations (REG-105479-18) under sections 959 and 961, and certain other provisions of the Internal Revenue Code of 1986, as amended...more
We recently hosted a webinar on Pillar Two and its practical impact on joint ventures (JVs). Our key takeaways are set out below.
Introduction to Pillar Two -
Pillar Two, also known as the global minimum tax, is an...more
On December 28, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”), announcing their plan to issue proposed regulations addressing the...more
On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more
On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more
On December 11, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”), announcing their intention to issue proposed regulations that will address...more
Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more
As discussed in our alert earlier this week, the recently announced proposed reconciliation package—the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”)—would impose a new 15% minimum tax on the adjusted financial...more
On July 27, 2022, Senators Manchin and Schumer announced that they agreed to a proposed reconciliation package, the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”). If enacted, the Bill would finance climate programs,...more