GILTI tax, Tax Planning, New Legislation

Major U.S. Tax Legislation Enacted Without Retaliatory Tax Provision

Davies Ward Phillips & Vineberg LLP on 7/21/2025

This bulletin follows our previous update on evolving U.S. tax reform, which highlighted the competing House and Senate proposals, particularly the introduction and scope of proposed Section 899 targeting "unfair foreign...more

Top 10 Biggest Business Tax Breaks (and Hits) in the One Big Beautiful Bill Act

Frost Brown Todd on 7/17/2025

With a name like the One Big Beautiful Bill Act (OBBBA), you know two things right away: (1) it’s a mouthful, and (2) you’re going to have to wade through a lot to find the useful parts. Fortunately, two tax lawyers already...more

Key International Tax Changes From the One Big Beautiful Bill Act

Bilzin Sumberg on 7/14/2025

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

What’s in the Newly Enacted One Big Beautiful Bill Act

Kelley Drye & Warren LLP on 7/14/2025

On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill Act” (the “2025 Act”). The Act makes permanent some provisions originally enacted in 2017 as part of the Tax Cuts and Jobs Act (the “2017 Act”),...more

GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect

Skadden, Arps, Slate, Meagher & Flom LLP on 5/24/2023

With more and more countries signing on to Pillar Two, “GILTI Conscience” hosts Nate Carden and David Farhat are joined by Vikram Chand, associate professor of law at the University of Lausanne, to discuss what this means for...more

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

McDermott Will & Schulte on 5/15/2019

On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

U.S. Tax Reform Has A Profound Impact On Inbound Investment

Orrick, Herrington & Sutcliffe LLP on 3/7/2018

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

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