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International Tax Issues › Tax Reform › Compliance

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

Hone Maxwell on

Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Akin Gump Strauss Hauer & Feld LLP

The Organization for Economic Co-Operation And Development (OECD) Global Tax Deal (Global Tax Deal)

Akin Gump Strauss Hauer & Feld LLP on

Issues a memorandum rejecting U.S. commitments related to the OECD Global Tax Deal unless enacted by Congress. It directs the Treasury and USTR to identify extraterritorial taxes and tax practices disproportionately impacting...more

Jones Day

IRS Increases Enforcement Efforts on Large Businesses

Jones Day on

The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act. The IRS Large Business and International ("LB&I")...more

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