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
In a significant development for multinational companies operating in the digital space, France’s Supreme Administrative Court (Conseil d’État) has referred the country’s Digital Services Tax (DST) regime to the...more
From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was...more
Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more
Guernsey, located in the English Channel, is one of the world’s largest offshore finance centres, with a thriving funds industry. The value of funds under management and administration in Guernsey is US$532bn. Guernsey is an...more
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
The Common Reporting Standard (CRS) was developed by the Organisation for Economic Co-operation and Development (OECD) to promote tax transparency by enabling tax authorities in one jurisdiction to receive information...more
The reconciliation bill, known as the “One Big Beautiful Bill” (the “BBB”), was recently signed into law on July 4th. The BBB, among many other things, made significant changes in tax law, building on the foundations created...more
Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act is similar to the Senate Finance Committee’s draft legislative text (the “SFC Bill”) (released on June 16, 2025), with...more
We present to you the Summer 2025 edition of the Asia Tax Bulletin. It contains tax developments in Asia on a host of topics, such as Hong Kong’s and Japan’s tax legislation to implement the Minimum Global Tax (also referred...more
On July 3, 2025, the U.S. Congress passed H.R. 1, “An Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14” (the “Act”). The Act was signed into law on July 4, 2025. The House of Representatives passed...more
In today’s competitive business environment, share incentive plans continue to be a popular tool for aligning employee interests with those of management and shareholders. Guernsey and Jersey, as leading offshore financial...more
The One Big Beautiful Bill Act is a massive bill that overhauls much of the U.S. tax system. Our Federal & International Tax and State & Local Tax teams cover the Act’s key tax provisions for individuals and businesses....more
Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
Edwin Cortés, socio, y Nicolás Carrero, abogado de derecho tributario, analizan el impuesto de timbre en contratos de cuantía indeterminada en este episodio de "A Lo Legal En Par Minutos". Como explican los abogados, un...more
Senate Finance Tax Title Goes Through ‘Byrd Bath’: Senate Parliamentarian Elizabeth McDonough has initiated the Byrd Bath process for the Senate Finance Committee’s (SFC) tax title within the reconciliation package. Senate...more
The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more
As we power through what remains of this quarter, working to get deals closed before quarter end next week, you may have noticed some additional (and new!) blacklining in the tax section of your credit agreement thanks to a...more
On June 16, 2025, the Senate Finance Committee released its version of the tax-related proposals (Senate Bill) for inclusion in the One Big Beautiful Bill Act (OBBBA). In line with the bill the House passed on May 22, 2025...more
In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more
Key Points - - The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent. - The bill...more
Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more
On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more
On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...more
The French tax authorities have issued new guidelines on the VAT treatment of company cars provided to employees. When a vehicle is provided for a defined consideration, it is considered a taxable service. This includes...more