First 60 Days of the Trump Administration: Food and Agriculture Policy
Business Better Podcast: Manufacturing Moment - Manufacturers’ Priorities for the New Administration
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
GILTI Conscience Podcast | Gearing Up for Pillar Two
#WorkforceWednesday: SCOTUS in Review, Biden Acts to Limit Non-Competes, NY HERO Act Model Safety Plans - Employment Law This Week®
SCOTUS Watch: The ACA and Key Health Law Areas Justice Barrett Could Impact - Diagnosing Health Care Podcast
2020 Presidential Candidates' Tax Proposals
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Texas v. United States of America
Qualified Opportunity Zone Fund Investments
Investment Management Update – Exit Strategies
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Taking Advantage of Opportunity Zones: A Panel Discussion
[WEBINAR] Labor & Employment Law: What Changed in 2017
Impact of Tax Reform on Charitable Giving
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBB) into law, making permanent the reduced individual tax rates and brackets established by the Tax Cuts and Jobs Act of 2017 and modifying a...more
On May 12, 2025, the House Committee on Ways and Means (WMC) released a draft of the tax provisions of the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill” Act (OBBB), and on May 14,...more
Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more
Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings - Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...more
In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more
The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more
The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more
Two years after the enactment of the Tax Cuts and Jobs Act (TCJA), the most significant tax reform enacted in a generation, taxpayers continue to encounter substantial uncertainty arising from interpretations of new statutory...more
On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more
Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more
Form 5472 is an Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The purpose of Form 5472 is to provide information when “reportable transactions” occur...more
In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society in the world” by Wired magazine. According to recent figures, Estonian...more
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section 250, which permits...more
The Tax Cuts and Jobs Act added section 951A to the Internal Revenue Code. This new section requires a U.S. shareholder of a Controlled Foreign Corporation (CFC) to include in gross income the shareholder’s Global Intangible...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
In the continuing stream of IRS guidance relating to the Tax Cuts and Jobs Act of 2017 (the “TJCA”), recent IRS guidance may impact not only a taxpayer’s tax situation, but ultimately the terms of a taxpayer’s credit...more
Our International Tax Group explores the hidden terrain for individuals found in the new tax on global intangible low-taxed income (GILTI). - The Section 250 deduction - The renewed importance of Section 962 - Beware of...more
The Tax Cuts and Jobs Act (TCJA) has far-reaching implications for the banking and finance industry. In our very first Bracewell Tax Report, we noted certain issues that companies might consider when evaluating their...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more
The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more