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A repository for the most well-read content on JD Supra at any given time, along with occasional roundups of popular content by specific topic. Also stop by for monthly recaps of hot articles for the previous... more +
A repository for the most well-read content on JD Supra at any given time, along with occasional roundups of popular content by specific topic. Also stop by for monthly recaps of hot articles for the previous thirty days. less -
Mintz - Tax Viewpoints

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

Mintz - Tax Viewpoints on

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

Wilson Sonsini Goodrich & Rosati

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

Wilson Sonsini Goodrich & Rosati on

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

Hone Maxwell

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

Hone Maxwell on

In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more

Akin Gump Strauss Hauer & Feld LLP

2025 Perspectives in Private Equity: Tax Analysis

Akin Gump Strauss Hauer & Feld LLP on

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

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

Allen Barron, Inc.

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

Allen Barron, Inc. on

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

Morgan Lewis

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

Morgan Lewis on

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

Blake, Cassels & Graydon LLP

Fiscalité internationale : Décisions de la Cour suprême du Canada

Blake, Cassels & Graydon LLP on

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

Blake, Cassels & Graydon LLP

International Tax Issues at the Supreme Court of Canada

Blake, Cassels & Graydon LLP on

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

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

Freeman Law

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

Bilzin Sumberg

IRS Issues Final Downward Attribution Regulations

Bilzin Sumberg on

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

Foodman CPAs & Advisors

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

Foodman CPAs & Advisors on

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

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