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New Guidance International Tax Issues Income Taxes

McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Goodwin

Luxembourg Tax Authority Issues New Guidance On Mutual Agreement Procedure

Goodwin on

On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more

McDermott Will & Schulte

[Event] Tax in the City® A Women's Roundtable - December 5th, Chicago, IL

McDermott Will & Schulte on

We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including: • Judicial deference and potential impact on TCJA audits • Taxation of the digitalized...more

Proskauer - Tax Talks

LIBOR Transition: U.S. Tax Guidance From the IRS

Proskauer - Tax Talks on

The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the...more

Jones Day

U.S. Treasury Releases Proposed FIRPTA Regulations

Jones Day on

New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more

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