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McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

McDermott Will & Schulte on

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

Holland & Knight LLP on

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

Kelley Drye & Warren LLP on

The One Big Beautiful Bill Act (the ​“Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more

Skadden, Arps, Slate, Meagher & Flom LLP

Executive and Administrative Changes Shape Tax Policy Ahead of Legislation - The Trump Administration’s First 100 Days

Skadden, Arps, Slate, Meagher & Flom LLP on

The Trump administration has declared that prior U.S. commitments under the OECD’s Pillar Two agreement would have no domestic effect unless approved by Congress, reflecting long-standing opposition....more

DLA Piper

Romania - VAT: Extension of the Applicability of RO e-Invoicing System to B2C Transactions - Monthly Indirect Tax Alert – January...

DLA Piper on

1 January 2025 marked the entry into force of the obligation for Romanian established taxpayers that carry out taxable operations in Romania to report in the Romanian invoicing System the invoices issued in B2C transactions....more

Akin Gump Strauss Hauer & Feld LLP

The Organization for Economic Co-Operation And Development (OECD) Global Tax Deal (Global Tax Deal)

Akin Gump Strauss Hauer & Feld LLP on

Issues a memorandum rejecting U.S. commitments related to the OECD Global Tax Deal unless enacted by Congress. It directs the Treasury and USTR to identify extraterritorial taxes and tax practices disproportionately impacting...more

Conyers

British Virgin Islands Removed from EU Tax Blacklist

Conyers on

Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

Stikeman Elliott LLP

Clean Energy Incentives: August 4, 2023 Legislative Proposals Relating to the Income Tax Act and Regulations

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance of Canada released significant legislative proposals relating to the federal government’s proposed measures to grow Canada’s clean economy. The release includes the draft...more

Cadwalader, Wickersham & Taft LLP

EU Directive Targets 'Shell' Companies

Cadwalader, Wickersham & Taft LLP on

On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more

Morgan Lewis

Initial Takeaways from the American Jobs Plan

Morgan Lewis on

The Biden-Harris administration announced its American Jobs Plan, a legislative framework laying out an ambitious $2 trillion investment in physical and human infrastructure, on March 31. The bulk of the proposed spending is...more

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