5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
An Ounce of Prevention Podcast | The International Anti-Corruption Prosecutorial Taskforce and the Future of Global Enforcement
GILTI Conscience Podcast | Tax Insurance 101
GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald
Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean
The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis
Navigating the Once-Obscure German Nonresident Withholding Tax
The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act
Musings on Multinational Tax: What to Expect From GILTI Conscience
Focus on APAC: A Look Back at 2020 and What Lies Ahead in 2021 and Beyond
Jannica Houben and Katarzyna Golonka on Complex Investigations
Nota Bene Episode 135: Europe Q3 Check In: Brexit, Data Protection, and Block Exemption Regulations with Oliver Heinisch
Nota Bene Podcast Episode 133: What’s Driving the Shift Toward Renewable Energy? with Paul Kaufman and Ben Huffman
Demystifying Immigration Law
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
Doing Business in the European Union | Global Laws & Compliance Program
Nota Bene Episode 115: European Q1 Check In: Brexit, Digital Markets Act, and the New Europe with Oliver Heinisch
Nota Bene Episode 112: How Europe is Filling Enforcement Gaps for Digital Gatekeepers with Robert Klotz and Ciara Barbu-O’Connor
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
The 2025 regular session of the Illinois General Assembly adjourned on June 1, 2025. The General Assembly passed a fiscal year (FY) 2026 budget package which includes corporate tax changes that will significantly impact...more
Although no major tax reform was adopted in Mexico as part of the 2023 Economic Package, changes at an international level and some being brought at the regulatory level could have significant implications for different...more
In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more
The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more
Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more
The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more
On June 14, 2019, the IRS and Treasury finalized the global intangible low-taxed income (GILTI) regulations (T.D. 9866) and issued proposed regulations (REG-101828-19) that will provide significant relief to investors in...more
In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more
On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the “Tax Cuts and Jobs Act”. While there have been multiple statements from the Republican majority in the...more
US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more
We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more
On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more
In structuring their workforces abroad, taxes are a major driving force for employers—and if recent government initiatives are any indicator, employers should take care when considering the tax implications of their staffing...more
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more
For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more