Taxing Intelligence: AI's Role in Modern Tax Administration
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
Impuesto de Timbre, ¿otra vez?
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
On 22 August 2025, the Luxembourg tax authorities issued a second circular (Circular) on the reverse hybrid entity rules, this time clarifying the exemption applicable to collective investment vehicles (CIV Exemption)....more
The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more
On May 22, 2025, the House passed the legislation entitled “The One Big Beautiful Bill” (the “BBB”). The BBB makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts and Jobs Act...more
On May 22, 2025, the U.S. House of Representatives passed the “One Big Beautiful Bill Act” (the “BBB”) as part of the Republican Congress’s reconciliation package. The BBB generally extends certain tax provisions of the 2017...more
Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more
On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more
The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts. The IRS has just released Notice 2022-36 which provides an...more
For decades, the United States (U.S.) has boasted the largest economy in the world and the largest market for imported goods. This article discusses basic strategies non-U.S. companies use to enter the U.S. market. Other...more
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
Proposed changes to Dutch tax law will make Dutch limited partnerships attractive private equity and venture capital fund and feeder fund alternatives to Irish and Luxembourg equivalents. A Dutch limited partnership...more
Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting. Our...more
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 17 – 21, 2020. February 18, 2020: The IRS issued a revenue ruling providing various...more
UK General Tax Developments - Date set for next UK Budget - The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment...more
The final Base Erosion and Anti-Abuse Tax regulations recently approved in T.D. 9885 generally follow the December 21, 2018, proposed regulations with a few important changes. The IRS also issued new proposed regulations at...more
On July 2, 2019, the Bureau of Economic Analysis released the 2018 numbers for foreign direct investment (FDI) in the US. Total 2018 FDI was $273 billion and of that figure, European investors accounted for $116 billion or...more
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more
n October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”) that are likely to allow many controlled foreign corporations...more
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
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