News & Analysis as of August 13, 2025

U.S. Treasury

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Nota Bene Episode 113: Common Markets and the Race for Power in Africa with Andreas Stargard
Nota Bene Episode 110: Mapping U.S. Domestic and Extraterritorial Trade Secret Protection and Enforcement with Robert Friedman

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Fenwick & West LLP on 4/30/2025

The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

IRS Rules Could Treat Related Party Debt as Stock

Foley & Lardner LLP on 5/2/2016

Multinational groups can strip U.S. earnings away from U.S. taxation by having a domestic corporation issue debt and pay earnings out to foreign affiliates as deductible interest. This strategy could be used after an...more

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Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

IRS Rules Could Treat Related Party Debt as Stock

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