News & Analysis as of

Proposed Regulation International Tax Issues 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

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

McDermott Will & Schulte

United Kingdom Repeals All But One of DAC6 Reporting Triggers

Despite much anticipation to the contrary, the UK Government decided to repeal all but one of the reporting triggers under the UK regulations implementing EU Council Directive 2018/822 on the reporting of cross-border tax...more

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