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Income Taxes › Foreign Derived Intangible Income (FDII) › Tax Cuts and Jobs Act

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... more +
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 -
Vinson & Elkins LLP

One Big Beautiful Bill Act: Key Tax Impacts for Businesses

Vinson & Elkins LLP on

On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance...more

Skadden, Arps, Slate, Meagher & Flom LLP

Senate Finance Committee Proposes Key Departures From House Provisions for the One Big Beautiful Bill Act

Skadden, Arps, Slate, Meagher & Flom LLP on

Key Points - - The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent. - The bill...more

Nutter McClennen & Fish LLP

Breaking Down the “One, Big, Beautiful” Tax Bill: Take One

Nutter McClennen & Fish LLP on

On May 12, the Republican majority leadership in the House of Representatives released for consideration its tax and spending reconciliation legislation, called the “One Big, Beautiful Bill” (the “Bill”). This major piece of...more

BakerHostetler

Tax Bill Proposes Trillions in Tax Cuts and Significant Tax Increases

BakerHostetler on

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

A&O Shearman on

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Proskauer - Tax Talks

Post Election – Expect Tax Legislation

Proskauer - Tax Talks on

With clear Republican victories in the White House and the Senate, and a very slim majority for either side in the House of Representatives, we can expect tax legislation in the coming year. It is expected that the President...more

Miller Nash LLP

Today in Tax: Eligibility of Electronic Services Income for FDII Deduction

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more

Freeman Law

Congress Readies New Round of Tax Increases

Freeman Law on

The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on

The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

A&O Shearman

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

McDermott Will & Schulte

Weekly IRS Roundup August 31 – September 4, 2020

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of...more

Faegre Drinker Biddle & Reath LLP

Substantiating an FDII Deduction: Certain Deal-Related Considerations Raised by New Regulations

Faegre Drinker Biddle & Reath LLP on

One of the cornerstones of the current U.S. international tax system, as revised under the 2017 tax law commonly known as the Tax Cuts and Jobs Act, is the deduction provided to U.S. corporate taxpayers under section 250(b)...more

McDermott Will & Schulte

Proposed Regulations under Sections 863(b) and 865(e)(2) Revise the Rules for Sourcing Income

McDermott Will & Schulte on

Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more

McDermott Will & Schulte

Illinois Fiscal Year 2020 Income and Franchise Tax Changes

McDermott Will & Schulte on

The Illinois General Assembly enacted a number of new tax measures in a flurry of activity at the end of its legislative session. Some of the changes are taxpayer friendly and others are not. Unlike the no-deal chaos of past...more

Proskauer - Tax Talks

Proposed FDII Regulations under Section 250

Proskauer - Tax Talks on

On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more

Eversheds Sutherland (US) LLP

The Last Piece of the Puzzle - the Section 250 Proposed Regulations

Eversheds Sutherland (US) LLP on

Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section 250, which permits...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Fenwick & West LLP

US Taxation of IP After Tax Reform

Fenwick & West LLP on

Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more

Fenwick & West LLP

Intellectual Property Bulletin - Summer 2018

Fenwick & West LLP on

In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more

Bracewell LLP

Bracewell Tax Report: April 2018 part 2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York State Responds to Federal Tax Reform

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On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

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