News & Analysis as of September 1, 2025

Income Taxes › Organization for Economic Co-operation and Development › Corporate Taxes

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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... 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 -

IRS announces intent to withdraw controversial DPL rules

McDermott Will & Schulte on 8/28/2025

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

One Big Beautiful Bill Act: Key Tax Impacts for Businesses

Vinson & Elkins LLP on 7/9/2025

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

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

Cooley LLP on 7/1/2025

On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

Update: US retaliatory taxes to be abandoned following G7 agreement on Pillar Two

Hogan Lovells on 7/1/2025

The United States has agreed with other G7 members to remove the section 899 protective tax measures from One Big Beautiful Bill in exchange for an agreement to exclude U.S. headed groups from major aspects of the OECD global...more

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

K&L Gates LLP on 6/16/2025

Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

New Section 899 – Enforcement of remedies against unfair taxes

Hogan Lovells on 5/19/2025

On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more

Caractérisation d’un établissement stable dans le domaine du digital en présence d’une activité occulte

Mayer Brown on 5/1/2025

Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...more

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

Morgan Lewis on 1/17/2025

The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

Tax innovations in Israel during 2024

Barnea Jaffa Lande & Co. on 10/10/2024

Over the past year, alongside handling the economic repercussions of the war and issuing financial assistance to war victims and to evacuees, the courts, the legislative authority and the Israel Tax Authority continued their...more

Bermuda Corporate Income Tax Considerations for Captive Insurers

Walkers on 9/12/2024

The operating provisions of the corporate income tax regime for Bermuda legislation will be effective for fiscal years beginning on or after 1 January 2025. This will apply to "Bermuda Constituent Entities" of an "In Scope...more

Guernsey announces further details of OECD Pillar Two implementation

Walkers on 5/23/2024

Following on from the Crown Dependencies re-affirming their commitment to implementing the Organisation for Economic Co-operation and Development’s Pillar Two framework for accounting periods commencing on or after 1 January...more

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

McDermott Will & Schulte on 5/2/2024

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

UK Tax Round Up - January 2024

Proskauer Rose LLP on 2/21/2024

Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on 2/5/2024

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Government of Bermuda Consulting on Possible Introduction of Corporate Income Tax

Conyers on 9/6/2023

In response to the Pillar Two global minimum tax rules (the GloBE Rules) set out by the Organisation for Economic Co-operation and Development (OECD), the Government of Bermuda has issued a public consultation paper...more

UK Tax Round Up - March 2023 - 2

Proskauer Rose LLP on 3/29/2023

Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more

Luxembourg Draft Budget Law 2023: The Most Awaited Reverse Hybrid Clarification

Goodwin on 10/26/2022

On 12 October 2022, the finance minister presented the Luxembourg budget bill for fiscal year 2023. For corporate tax payers, and particularly for funds, there is a most welcomed clarification on the scope of the...more

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on 9/29/2022

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Today in Tax: U.S. Tax Treaty Updates—Chile, Croatia, and Hungary

Miller Nash LLP on 8/5/2022

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more

UK Tax Round Up - May 2022

Proskauer Rose LLP on 6/8/2022

Welcome to May's edition of the UK Tax Round Up. This month has seen a number of interesting court decisions, an important opinion of the European Commission’s Advocate General and the commencement of a Treasury consultation...more

OECD Issues Model Rules on Nexus and Sourcing

Freeman Law on 2/14/2022

On February 4, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued model rules for nexus and revenue sourcing under Pillar One of the international tax agreement (the so-called “two-pillar...more

Taxation & Representation, February 8, 2022

Brownstein Hyatt Farber Schreck on 2/9/2022

Legislative Lowdown - Build Back Better Reboot. Rep. Richard Neal (D-MA), the House Ways and Means Committee chair, and Sen. Ron Wyden (D-OR), chair of Senate Finance Committee, are cautiously optimistic negotiations over...more

UK Tax Round Up - June 2021

Proskauer Rose LLP on 7/6/2021

UK Case Law Developments - Income tax consequences of pension-related payments in E.ON v HMRC - E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more

130 countries join the OECD’s framework for international tax reform

Proskauer - Tax Talks on 7/6/2021

Significant progress has been made in the efforts of the OECD to reach international consensus on the BEPS 2.0 proposals. Broadly, the proposals are aimed at addressing challenges relating to taxation of the modern digital...more

UK Tax Round Up - February 2021

Proskauer Rose LLP on 3/10/2021

UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more

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