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Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more
Congress made a number of changes in the One Big Beautiful Bill Act (H.R. 1), signed into law on July 4, 2025, impacting the Foreign-Derived Intangible Income (FDII) deduction in Section 250. Click here for a link to a...more
Two countries form a treaty under the general principles of contract law. A fundamental aspect of contract law requires a meeting of the minds – a shared understanding of the agreed terms. Accordingly, unless expressly...more