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Foreign Entities International Tax Issues

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

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The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

Offit Kurman

Not Knowing the Tax Implications of How Your Client is Classified?

Offit Kurman on

Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups....more

Cadwalader, Wickersham & Taft LLP

American Cousins: HMRC Revisits Anson

On 12 December 2023, H.M. Revenue & Customs (“HMRC”) updated its guidance on foreign entity classification and, specifically, HMRC’s treatment of profits of, and distributions by, United States-established limited liability...more

Cadwalader, Wickersham & Taft LLP

Measures Against Russia (Only)? UK Economic Crime (Transparency and Enforcement) Act 2022

Rushed through the Parliament in response to Russia’s invasion of Ukraine, the new Economic Crime (Transparency and Enforcement) Act (the “Act”) received Royal Assent on 15 March 2022....more

Bilzin Sumberg

Navigating Pandora’s Hallelujah Mountains: Civil Law Foundations, U.S. Tax Classification and Related Penalty Issues

Bilzin Sumberg on

One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more

McDermott Will & Emery

[Event] West Coast Tax Forum: California & Beyond: The Impact Of State, Federal And International Tax Developments On Golden State...

McDermott Will & Emery on

Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges. Join members...more

Fox Rothschild LLP

LB&I Announces Five More Compliance Campaigns, Bringing Total To 50 Campaigns

Fox Rothschild LLP on

The Internal Revenue Service’s Large Business and International division (LB&I) announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first 13 campaigns,...more

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