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The Proposed US Tax Regime for Non-US Investors and Companies

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Curve-Flattening Travel Immobility Leads to Cross-Border Tax Challenges for Companies and Employees

Covid-19 is creating unexpected tax exposure for foreign-based businesses with employees detained in the US and vice versa as companies may now find themselves with more sourced income than expected causing unforeseen tax...more

The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends

The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more

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