Popular, International Tax Issues, Income Taxes

New Option for Excess Fee Income Rebates in Private Equity Funds for Non-US and US Tax-Exempt Investors

Mintz - Tax Viewpoints on 7/14/2025

This update discusses a new and interesting development with respect to how certain non-US and US tax-exempt investors can receive a “rebate” of previously paid management fees with respect to their investments in private...more

One Big Beautiful Bill Act: Key Tax Impacts for Businesses

Vinson & Elkins LLP on 7/9/2025

On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance...more

The One Big Beautiful Bill Act: An Initial Analysis of Key Tax Proposals

Skadden, Arps, Slate, Meagher & Flom LLP on 5/29/2025

On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more

2025 Perspectives in Private Equity: Tax Analysis

Akin Gump Strauss Hauer & Feld LLP on 4/18/2025

Major portions of the U.S. tax code are scheduled to expire at the end of 2025, and as the U.S. tax landscape faces potential upheaval, private equity firms must stay vigilant and adaptable. Proactively engaging with tax...more

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

Kazakhstan Stock Exchange: Significant Change to Taxation of Dividends on Certain Shares

Morgan Lewis on 7/25/2022

The rules for taxation of dividends in respect of shares that are included in the official listing of a stock exchange in Kazakhstan will significantly change as of 1 January 2023....more

A Non-U.S. Company’s Guide to Doing Business in the U.S.: A Playbook for Accessing the U.S. Market

Miller Nash LLP on 7/13/2022

For decades, the United States (U.S.) has boasted the largest economy in the world and the largest market for imported goods. This article discusses basic strategies non-U.S. companies use to enter the U.S. market. Other...more

Fiscalité internationale : Décisions de la Cour suprême du Canada

Blake, Cassels & Graydon LLP on 1/6/2022

La Cour suprême du Canada (la « CSC ») a récemment rendu d’importantes décisions dans deux différends qui portaient sur des questions de fiscalité internationale. Dans l’affaire Canada c. Alta Energy Luxembourg S.A.R.L., 2021...more

International Tax Issues at the Supreme Court of Canada

Blake, Cassels & Graydon LLP on 12/20/2021

The Supreme Court of Canada (SCC) recently released two important decisions relating to international tax issues. The SCC provided meaningful guidance on the interpretation of one of Canada’s bilateral tax treaties and the...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

UK Employment Flash - February 2021

Skadden, Arps, Slate, Meagher & Flom LLP on 2/22/2021

In this issue of UK Employment Flash, we examine the latest employment law developments, news and insights from the UK, including considerations for employers requiring staff to get the COVID-19 vaccine, the delayed rollout...more

International Tax Treaty: China

Freeman Law on 12/9/2020

Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on 10/14/2020

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

IRS Issues Final Downward Attribution Regulations

Bilzin Sumberg on 10/6/2020

On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b)....more

Treasury and IRS are Aiming to Provide Greater Clarity on International Tax Reporting

Foodman CPAs & Advisors on 8/7/2020

On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...more

IRS extends more Covid-19 Relief for many including Americans who live and work abroad

Foodman CPAs & Advisors on 5/1/2020

The IRS continues to process electronic tax returns, issue direct deposit refunds and accept electronic payments while simultaneously granting additional, broad tax filing and payment deadline relief to all Taxpayers that...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

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

Section 385 Treasury Regulations Developments

A&O Shearman on 11/5/2019

Related Party Debt Documentation Rules Are Removed and Future Changes to Limit Recharacterization Rules Are Expected - On October 31, 2019, the Treasury Department and the Internal Revenue Service (IRS) made two significant...more

Taxation & Representation - June 2019 #3

Brownstein Hyatt Farber Schreck on 7/3/2019

TAX TIDBIT - Five Takeaways and a Falsehood: Test Your Knowledge of the Ways and Means Tax Markup - On Thursday, the House Ways and Means Committee marked up and approved the following four bills, largely along...more

Analysis of Key Provisions of the Tax Cuts and Jobs Act

Ballard Spahr LLP on 1/9/2018

As we are sure you know, H.R. 1, informally known as the Tax Cut and Jobs Act, became law on December 22, 2017. This new law will impact almost all taxpayers. Ballard Spahr's Tax Group has prepared a detailed summary of...more

Seventeen Provisions to Watch in the Senate Tax Reform Bill

Cadwalader, Wickersham & Taft LLP on 12/13/2017

On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

Proskauer - Tax Talks on 12/12/2017

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more

Tackling Tax Reform – Part IV: What Can We Expect To See

Foster Garvey PC on 5/19/2017

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

2016 Year-End Tax Update: Okay, Now What?

Cozen O'Connor on 1/6/2017

In last year’s materials, loosely styled “Make America Great Again!,” we ruminated upon (and also thought about) what role, if any, federal income taxes might play in helping to make America great again, once the interminable...more

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