On June 16, 2025, the Senate Finance Committee released its draft of the tax provisions in H.R. 1 (commonly referred to as the “One Big Beautiful Bill” (the SFC Bill)). We previously covered the original legislation passed by...more
On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill).1 The House Bill will next be considered by the U.S. Senate. The House Bill includes a number...more
On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more
Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more
9/6/2019
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Earned Income ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Treaty ,
U.S. Treasury
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more