Tax Cuts and Jobs Act, Foreign Tax Credits, Foreign Derived Intangible Income (FDII)

A Look at the International Tax Changes in the One Big Beautiful Bill Act

Holland & Knight LLP on 7/21/2025

The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on 9/23/2021

The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

U.S. Tax Legislation Alert: Wyden Bill Proposes…

Fenwick & West LLP on 9/10/2021

Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the...more

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on 10/14/2020

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on 1/29/2020

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

Proposed Regulations under Sections 863(b) and 865(e)(2) Revise the Rules for Sourcing Income

McDermott Will & Schulte on 1/6/2020

Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• 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

Tax Cuts and Jobs Act › Foreign Tax Credits › Foreign Derived Intangible Income (FDII)