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Internal Revenue Service › International Tax Issues › Proposed Rules

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 March 17, 2025

Eversheds Sutherland (US) LLP on

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

Latham & Watkins LLP

Passive Foreign Investment Companies: Reinterpreting the Active Banking Exception for the Modern Banking Industry

Latham & Watkins LLP on

The passive foreign investment company (“PFIC”) rules generally impose unfavorable tax treatment on certain U.S. shareholders of foreign corporations that generate excess passive income or hold excess passive assets. In...more

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