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International Tax Issues

Proskauer Rose LLP

UK Tax Round Up - July 2025

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Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more

Carey Olsen

Guernsey funds – special considerations for US managers

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Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

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Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

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Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Carey Olsen

CRS 2.0 amendments to the OECD’s Common Reporting Standard

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The Common Reporting Standard (CRS) was developed by the Organisation for Economic Co-operation and Development (OECD) to promote tax transparency by enabling tax authorities in one jurisdiction to receive information...more

Paul Hastings LLP

One Big Beautiful Bill Act — A Private Equity Perspective

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On July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA). This alert summarizes the key changes under the OBBBA relevant to private equity sponsors and their investors, as well as some of the...more

BakerHostetler

Analysis of Opportunity Zone and Related Tax Credit Changes Under the 2025 Tax Legislation

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In this alert, which is part of an eight-part series taking a deeper dive into various portions of the Legislation (International Tax; Opportunity Zone and Tax Credits; Green Energy Credits; Estate Planning and Individual Tax...more

Allen Barron, Inc.

Expanding Your International Business to San Diego or the United States

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Are you considering expanding your international business to San Diego or the United States? Are you planning to start a new business entity to add to the existing constellation of your companies, or are you considering a...more

Royer Cooper Cohen Braunfeld LLC

One Big Beautiful Bill Expands Key Tax Incentives Including Section 1202 Qualified Small Business Stock and Qualified Opportunity...

The reconciliation bill, known as the “One Big Beautiful Bill” (the “BBB”), was recently signed into law on July 4th. The BBB, among many other things, made significant changes in tax law, building on the foundations created...more

Hone Maxwell

Understanding FATCA and Its Impact on Foreign Financial Institutions: Why Finding Financial Services as an American Abroad Can Be...

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As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more

Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

Proskauer - Tax Talks

President Trump Signs One Big Beautiful Bill Act into Law

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act is similar to the Senate Finance Committee’s draft legislative text (the “SFC Bill”) (released on June 16, 2025), with...more

Cooley LLP

Key International Tax Provisions Under the One Big Beautiful Bill Act

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On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. It is a landmark piece of legislation that introduces several important changes to the US international tax regime. This alert provides an overview...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses

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The Trump administration’s fluctuating tariffs pose major compliance risks for businesses operating in the U.S. Dive into the challenges they pose to businesses that rely on imported goods and services as Marina Gentile...more

Holland & Knight LLP

A Look at the International Tax Changes in the One Big Beautiful Bill Act

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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

BakerHostetler

Analysis of International Tax Changes Under the 2025 Tax Legislation

BakerHostetler on

The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more

Davies Ward Phillips & Vineberg LLP

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

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

ArentFox Schiff

OBB-BA-Di, Ob-La-Da, Life Goes On, Brah? Life – and Tax Policy – Goes On

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On July 4, President Donald Trump signed into law P.L. 119-21, the “One Big Beautiful Bill Act” (OBBBA), enacting significant changes to the US tax system....more

Mayer Brown

Asia Tax Bulletin - Summer 2025

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We present to you the Summer 2025 edition of the Asia Tax Bulletin. It contains tax developments in Asia on a host of topics, such as Hong Kong’s and Japan’s tax legislation to implement the Minimum Global Tax (also referred...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Act: Key Tax Provisions and Analysis

On July 4, 2025, President Donald Trump signed into law the Act (formerly referred to as the One Big Beautiful Bill Act, or OBBBA). The Act includes a suite of tax-related provisions that (1) make permanent many of the...more

McDermott Will & Emery

Corporate taxpayers: Key One Big Beautiful Bill Act changes to international and domestic taxes

McDermott Will & Emery on

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

Bracewell LLP

Big Tax Changes in the One Big Beautiful Bill Act

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On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the OBBBA), which makes permanent or modifies key provisions of the 2017 Tax Cuts and Jobs Act (the TCJA) and scales back numerous energy tax...more

K&L Gates LLP

Tax Changes in the Final Budget Reconciliation Bill

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On 3 July 2025, the House passed the Senate’s version of H.R. 1, the budget reconciliation bill formerly known as the “One Big Beautiful Bill Act” (the Act). President Trump signed the Act into law on 4 July 2025. The...more

WilmerHale

One Big Beautiful Bill Act

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On July 4, 2025, the President signed into law the “One Big Beautiful Bill Act” (the “Act”). Among other things, the Act makes permanent many provisions of the 2017 Tax Cuts and Jobs Act (the “TCJA”) that otherwise would...more

WilmerHale

International Tax Provisions of the One Big Beautiful Bill Act (OBBBA)

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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

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