News & Analysis as of

Organization for Economic Co-operation and Development › Tax Reform › Cross-Border Transactions

Eversheds Sutherland (US) LLP

IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

Eversheds Sutherland (US) LLP on

On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Business Tax Reform All but Certain in US, Europe"

Skadden, Arps, Slate, Meagher & Flom LLP on

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

McGuireWoods LLP

OECD Releases Final BEPS Recommendations – Now What?

McGuireWoods LLP on

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

Troutman Pepper

International Tax Grows Up: The Tax Section at 75, Subpart F at 53, and the Foreign Tax Credit at 97

Troutman Pepper on

As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more

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