Corporate Taxes, Foreign Derived Intangible Income (FDII), U.S. Treasury

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

Venable LLP on 6/5/2025

As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Davies Ward Phillips & Vineberg LLP on 3/4/2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Treasury’s Green Book Provides Details on the Biden Administration’s Tax Plan

Proskauer - Tax Talks on 6/16/2021

On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on 10/14/2020

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

Proposed Regulations under Sections 863(b) and 865(e)(2) Revise the Rules for Sourcing Income

McDermott Will & Schulte on 1/6/2020

Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

Womble Bond Dickinson on 8/25/2019

On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more

US Treasury Issues Proposed Regulations on the Beneficial IRC Section 250 Corporate Tax Deduction Related to Export Sales of...

Womble Bond Dickinson on 3/29/2019

US Treasury has now published detailed guidance on a significant US corporate tax rate benefit for any US company that conducts direct sales of property and/or services to foreign persons for foreign use. The tax rate benefit...more

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