President Donald Trump recently signed into law the bill commonly known as the One Big Beautiful Bill Act (OBBBA). On July 4, 2025, the OBBBA made permanent many of the provisions of the Tax Cuts and Jobs Act of 2017 (TCJA)...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
Our International Tax Group examines the high-tax exclusion (HTE) in new final regulations under the global intangible low-taxed income (GILTI) regime and the potentially precarious side effects U.S. shareholders face in...more
On July 23, 2020, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations addressing the global intangible low-taxed income (GILTI) high-tax exclusion (85 FR 44620) (the “Final...more
On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more
It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more
According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more
A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC...more
In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more