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Latham & Watkins LLP

One Big Beautiful Bill: Key Business and Investment Impacts

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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

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

Venable LLP on

As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

A&O Shearman on

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Walkers

Guernsey and Jersey re-affirm commitment to OECD Pillar Two implementation

Walkers on

The Crown Dependencies have re-affirmed their commitment to international tax standards and the continued value of inter-island cooperation in areas of mutual interest in international tax policy. Ministers from...more

Mayer Brown

Tax Law Highlights | Brazilian Tax Reform And Expectations For Its Regulation

Mayer Brown on

The Brazilian Tax Reform on consumption was enacted through Complementary Amendment No. 132/2023, which unified the main taxes on the consumption of goods and services in the form of a Dual VAT and through the creation of a...more

Mayer Brown

Brazil Tax News: Laws, Provisional Measures, Normative Instructions, and Bill of Law Approved at End of December 2023

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Several new rules were approved on December 28, 2023, all extremely relevant to tax law. Our tax team summarizes some of the more relevant new rules...more

Morgan Lewis

Dividend Taxation in Kazakhstan: Additional Condition to Apply Double Tax Treaty

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Recent changes to the Kazakhstan Tax Code introduced an additional condition for applying a double tax treaty when paying dividends in Kazakhstan. To illustrate the current regime, consider the following scenario wherein...more

Akin Gump Strauss Hauer & Feld LLP

UK Spring Budget 2023: Points for Asset Managers

Introduction - On 15 March 2023, the UK government revealed the widely anticipated Spring Budget, which contained a number of measures that may be of interest to asset managers....more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 14, 2022

Kustoff Joins Ways and Means. Rep. David Kustoff (R-TN) has been selected to replace former Rep. Tom Reed (R-NY), who resigned from Congress earlier this year, on the House Ways and Means Committee. He will sit on the Worker...more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

McDermott Will & Schulte

[Webinar] Tax in the City® - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...more

Proskauer - Tax Talks

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

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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

BakerHostetler

[Podcast] Intellectual Property Tax Considerations at Home and Abroad

BakerHostetler on

Businesses that conduct operations both inside and outside of the United States and own U.S. and non-US-related intellectual property (e.g., patents, copyrights, trademarks, etc.) routinely face uncertainty about whether some...more

Proskauer Rose LLP

UK Tax Round Up - November 2021

Proskauer Rose LLP on

Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more

Miller Nash LLP

When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)

Miller Nash LLP on

The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Bilzin Sumberg

The Draft of the International Tax Overhaul: Where is Captain America?

Bilzin Sumberg on

On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more

Cadwalader, Wickersham & Taft LLP

A Look at the Biden Administration’s Fiscal Year 2022 Revenue Proposals

I. Introduction - On May 28, 2021, the Treasury Department released the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook). ...more

Proskauer Rose LLP

UK Tax Round Up - November 2020

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UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more

Freeman Law

International Tax Treaty: The United Kingdom

Freeman Law on

Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more

Morgan Lewis

Rules on Controlled Foreign Corporations in Kazakhstan May Change

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The Kazakhstan Tax Code may change so that controlled foreign corporation rules will not apply to foreign persons that are residents of countries having a double tax treaty with Kazakhstan. Kazakhstan residents (both...more

BakerHostetler

BEPS 2.0 - International Tax Reform Primer for SALT Experts

BakerHostetler on

It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more

Bilzin Sumberg

Feeling GILTI Enough to Make a Section 962 Election?

Bilzin Sumberg on

After the passage of Public Law No. 115-97, formerly known as the Tax Cuts and Jobs Act (the “Tax Reform Act”), U.S. individual shareholders of controlled foreign corporations (“CFCs”) were faced with a difficult decision. ...more

Bilzin Sumberg

La reducción en la tasa impositiva corporativa en EE. UU. tendrá un impacto significativo en la planificación saliente de...

Bilzin Sumberg on

La Ley de Reducción de Impuestos y Empleos (Tax Cuts and Jobs Act, TCJA) representa el conjunto de medidas de reforma fiscal más significativo que fue promulgado desde 1986. ...more

Bilzin Sumberg

Las consecuencias (¿accidentales?) de la reforma fiscal sobre las estructuras de financiación entrantes

Bilzin Sumberg on

La mayor parte de la atención en torno a los aspectos internacionales de la Ley Pública n.° 115-97, anteriormente conocida como la Ley de Recortes Tributarios y Empleos (la “Ley de Reforma Fiscal”)... Originally published...more

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