Popular, GILTI tax, IRS

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on 7/8/2025

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Davies Ward Phillips & Vineberg LLP on 3/4/2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on 9/7/2021

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

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

McDermott Will & Schulte on 10/21/2020

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

Weekly IRS Roundup August 10 – August 14, 2020

McDermott Will & Schulte on 8/19/2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 10, 2020 – August 14, 2020... August 10, 2020: The IRS published corrections to a notice...more

Taxation & Representation - February 2020

Brownstein Hyatt Farber Schreck on 3/5/2020

TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more

Final and Proposed BEAT Regulations Provide Some Relief

McDermott Will & Schulte on 12/18/2019

Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more

Final and Proposed TCJA Foreign Tax Credit Regulations Create Traps and Opportunities

A&O Shearman on 12/17/2019

On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more

Treasury and IRS Issue Final Regulations on Base Erosion and Anti-Abuse Tax (The BEAT)

A&O Shearman on 12/11/2019

On December 2, 2019, the Treasury Department and the Internal Revenue Service (the “IRS”) issued final and proposed regulations (the “Final Regulations” and the “2019 Proposed Regulations,” respectively) regarding the base...more

IRS provides very modest relief from downward attribution resulting from the repeal of section 958(b)(4)

Proskauer - Tax Talks on 11/13/2019

On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more

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