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Multinationals International Tax Issues

McDermott Will & Schulte

France’s Digital Services Tax Faces Constitutional Crossroads

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

Holland & Knight LLP

A Look at the International Tax Changes in the One Big Beautiful Bill Act

Holland & Knight LLP on

The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more

BakerHostetler

Analysis of International Tax Changes Under the 2025 Tax Legislation

BakerHostetler on

The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

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

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions in Final Legislation Impacting Domestic and Multinational Businesses

On July 4, 2025, President Trump signed H.R. 1, commonly known as the “One Big Beautiful Bill Act” (OBBB), into law. OBBB was initially approved by the House of Representatives on May 22, 2025 (the House Bill), followed by...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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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

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

Kilpatrick on

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

Davies Ward Phillips & Vineberg LLP

Retaliatory Taxes: Pending Legislation in U.S. Congress May Adversely Impact Returns on Inbound Investment

As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

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As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

White & Case LLP

Mexican Tax Authority (SAT) Substantially Increases Transfer Pricing Tax Collections

White & Case LLP on

On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting Domestic and Multinational Businesses

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill). The House Bill will next be considered by the U.S. Senate, and the administration has set a...more

Fenwick & West LLP

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

Fenwick & West LLP on

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

Goodwin

Pillar II in Luxembourg: What Investment Funds Need to Know

Goodwin on

The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more

Womble Bond Dickinson

[Event] Top Considerations in Building Presence in a Foreign Country - October 3rd, Houston, TX

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Join Womble Bond Dickinson and Houston ACC for a panel discussion on the legal aspects and practical considerations when expanding your operations internationally. We’ll cover different types of presences, tax considerations,...more

Goodwin

The South Korean K-Chips Act and Its Impact on International Companies and Investors

Goodwin on

For investors in enterprises in the Korean semiconductor industry and other national strategic industries, a new tax bill has been passed that (i) increases the base tax credits received by these enterprises to 25% (if...more

A&O Shearman

UK moves closer to a Pillar Two reality

A&O Shearman on

The UK continues to progress its implementation of the OECD’s Pillar Two reforms, with further legislative progress and publication of draft guidance by HMRC....more

Morgan Lewis

The Dawn of BEPS 2.0 in Singapore: An Uncertain Road, A Certain Destination

Morgan Lewis on

The global wave of the two-pillar solution to address base erosion and profit shifting, commonly known as BEPS 2.0, has formally washed ashore in Singapore. It is now certain that multinational enterprises (MNEs) with local...more

Freeman Law

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald

In the new episode of our tax podcast, “GILTI Conscience,” EY’s Michael McDonald discusses whether the OECD’s DEMPE transfer pricing guidelines are being properly interpreted, including whether some jurisdictions are placing...more

McDermott Will & Schulte

[Webinar] Tax in the City® - March 1st, 11:30 am - 1:00 pm PDT

The potential impact of global mobility issues and recent tax developments may require reassessing your planning strategies. Join us for our first Tax in the City® program of 2022, which will cover federal and...more

BakerHostetler

[Podcast] Intellectual Property Tax Considerations at Home and Abroad

BakerHostetler on

Businesses that conduct operations both inside and outside of the United States and own U.S. and non-US-related intellectual property (e.g., patents, copyrights, trademarks, etc.) routinely face uncertainty about whether some...more

Skadden, Arps, Slate, Meagher & Flom LLP

Musings on Multinational Tax: What to Expect From GILTI Conscience

Skadden is proud to present "GILTI Conscience," a new podcast series in which tax partners Nate Carden and David Farhat invite other industry leaders and authorities to join them in discussing pressing transfer pricing...more

Miller Nash LLP

When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)

Miller Nash LLP on

The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social...more

Brownstein Hyatt Farber Schreck

OECD Announces Global Tax Deal

The Organization for Economic Cooperation and Development (OECD) announced earlier today that 136 countries reached agreement on the Inclusive Framework on Base Erosion and Profit Shifting. The two-pillar framework would...more

McDermott Will & Schulte

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

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Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more

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