News & Analysis as of August 21, 2025

Regulatory Requirements

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Fenwick & West LLP on 4/30/2025

The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

McDermott Will & Schulte on 3/11/2025

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

Proskauer - Tax Talks on 2/13/2025

On December 2, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) on section 752 regarding the allocation of partnership...more

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Income Taxes › Final Rules › Regulatory Requirements

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

Final Regulations Issued on Allocation of Partnership Liabilities Under Section 752

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