International Tax Issues, Corporate Taxes, Foreign Tax

Is Revenge a Dish Best Served Under the Tax Code?

Cadwalader, Wickersham & Taft LLP on 6/24/2025

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as...more

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

Eversheds Sutherland (US) LLP on 12/18/2023

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

The Revenue Rule in the Cayman Islands and British Virgin Islands

Conyers on 8/27/2021

It is well established, under common law principles applicable in the Cayman Islands and the British Virgin Islands that claims for payment of foreign tax liabilities, or claims for the enforcement of foreign judgments for...more

Is Tax Competition Dead?

Skadden, Arps, Slate, Meagher & Flom LLP on 6/21/2021

The G7’s support for OECD-backed tax reforms could mark a big step toward a more consistent, revamped global tax scheme — depending on the details and whether it is actually adopted. ...more

Biden Administration's FY 2022 Budget and International Tax Changes

Holland & Knight LLP on 6/11/2021

A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

Jones Day on 12/5/2017

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

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