News & Analysis as of

Proposed Regulation International Tax Issues Organization for Economic Co-operation and Development

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

Focus on Tax Strategies & Developments - April 2017

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

McDermott Will & Emery

Rewriting the Fundamentals of International Taxation: the OECD BEPS Action Plan

McDermott Will & Emery on

The Organization for Economic Co-operation and Development has released its ambitious action plan to address base-erosion and profit-shifting. If the political will exists to enact the changes envisaged by the action plan,...more

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