AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
The United States recently passed tax legislation called the One Big Beautiful Bill Act (OBBBA), a follow-up to the 2017 Trump tax cuts. While the bill is American, many Canadian families with cross-border ties, including...more
On July 4, President Trump signed into law the One Big Beautiful Bill Act (the Act). While the Act covers a wide swath of territory, the core of the Act is its tax provisions. The Act (i) makes permanent many of the tax...more
On July 4, 2025, President Trump signed into law the FY 2025 budget bill (the “Act”), which includes substantial business tax proposals. At a high level, the Act permanently extends many of the 2017 Tax Cuts and Jobs Act’s...more
The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more
On July 4, 2025, US President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law. The legislation introduces significant changes to both international and domestic business tax rules for US taxpayers. While...more
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking a significant overhaul of the international tax landscape. This legislation introduces several key changes aimed at refining...more
On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more
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
On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more
In late October 2024, the United States Court of Appeals for the Eleventh Circuit ruled in Romano v. Hancock Life Insurance Company, F.4th 729 (11th Cir. 2024) that certain foreign tax credits that were generated as a result...more
Last week, President Donald Trump issued two Executive Orders (EOs) that address digital services taxes enacted by international trading partners and income taxes paid by US taxpayers to the People’s Republic of China (PRC),...more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
Bruyea v. United States (Ct. Claims Dec. 5, 2024), is the latest in a series of cases concerning whether a U.S. double tax treaty, in this case Canada's, allows a foreign tax credit for Canadian income taxes against the 3.8%...more
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9, 2024 – September 13, 2024....more
The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more
Liberty Global has announced that it will challenge the November 2023 Tax Court finding that the company had incorrectly boosted its foreign tax credits by failing to account for gains that exceeded the total foreign loss on...more
This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
On December 11, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”), announcing their intention to issue proposed regulations that will address...more
In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more