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Internal Revenue Service › Cross-Border Transactions › Reorganizations

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Eversheds Sutherland (US) LLP

Tax Bytes: Week of September 1, 2025

Eversheds Sutherland (US) LLP on

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

Hogan Lovells

IRS reduces barriers to redomiciliations

Hogan Lovells on

On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more

Cadwalader, Wickersham & Taft LLP

Treasury Finalizes “Killer B” Regulations with Few Adjustments

Cadwalader, Wickersham & Taft LLP on

On July 17, the U.S. Treasury and IRS released final regulations targeting various inbound cross-border transactions broadly referred to as “Killer B” transactions, marking the end (for now) of a long-running regulatory fight...more

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