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Digital Services Tax U.S. Treasury

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more

McDermott Will & Schulte

New Attribution Requirement Denies Foreign Tax Credits For Certain Withholding Taxes (And Other Taxes)

On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more

Alston & Bird

Digital Services Taxes and Nexus for Foreign Tax Credit Purposes

Alston & Bird on

Our International Tax Group reviews Treasury’s proposed regulations that would add a jurisdictional nexus requirement to the analysis used to determine whether a foreign tax is an income tax for foreign tax credit purposes....more

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