International Tax Issues, Foreign Tax Credits, Foreign Derived Intangible Income (FDII)

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

Holland & Knight LLP on 7/21/2025

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

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

Proskauer - Tax Talks on 12/20/2021

Yesterday, on December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage. While there are no immediate prospects for the Build Back Better Act to...more

“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 9/23/2021

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

Responsibly Funding Our Priorities – House Yields Decisive Reconciliation Action

Bilzin Sumberg on 9/20/2021

As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more

Senate Finance Committee Provides International Taxation Framework After President Biden Unveils the American Jobs Plan

ArentFox Schiff on 4/8/2021

The proposals in the Framework echo many of the themes set forth in the Made in America Tax Plan. Last week, President Biden outlined an infrastructure spending plan (the American Jobs Plan) and a tax reform plan (the...more

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

A&O Shearman on 10/14/2020

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

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

McDermott Will & Schulte on 1/6/2020

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

International Tax Issues › Foreign Tax Credits › Foreign Derived Intangible Income (FDII)