On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill Act” (the “2025 Act”). The Act makes permanent some provisions originally enacted in 2017 as part of the Tax Cuts and Jobs Act (the “2017 Act”),...more
The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more