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International Tax Issues › Tax Planning › Pass-Through Entities

Latham & Watkins LLP

One Big Beautiful Bill: Key Business and Investment Impacts

Latham & Watkins LLP on

On July 4, 2025, President Trump signed into law H.R. 1, known as the One Big Beautiful Bill Act (the Act). The Act changes key features of US tax law. Notably, the Act: ..Makes permanent the Section 199A2...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

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

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