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Tax Cuts and Jobs Act International Tax Issues Tax Planning

Latham & Watkins LLP

One Big Beautiful Bill: Key Business and Investment Impacts

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On July 4, 2025, President Trump signed into law H.R. 1, known as the One Big Beautiful Bill Act (the Act). The Act changes key features of US tax law. Notably, the Act: ..Makes permanent the Section 199A2...more

Paul Hastings LLP

One Big Beautiful Bill Act — A Private Equity Perspective

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On July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA). This alert summarizes the key changes under the OBBBA relevant to private equity sponsors and their investors, as well as some of the...more

Davies Ward Phillips & Vineberg LLP

Major U.S. Tax Legislation Enacted Without Retaliatory Tax Provision

This bulletin follows our previous update on evolving U.S. tax reform, which highlighted the competing House and Senate proposals, particularly the introduction and scope of proposed Section 899 targeting "unfair foreign...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Opportune LLP

Tax Planning Transformed: A Look at 20 Years of Evolution

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For many years, taxes were the quiet endnote in financial decisions, an obligatory step taken after the strategic direction had been set. In mergers and acquisitions, IPO planning, and corporate restructurings, tax...more

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

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As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

Whiteford

Client Alert: Inside the One Big Beautiful Bill Crucial Tax Updates for Individuals, Business Owners, and Nonprofits

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On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

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On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Akin Gump Strauss Hauer & Feld LLP

2025 Perspectives in Private Equity: Tax Analysis

Major portions of the U.S. tax code are scheduled to expire at the end of 2025, and as the U.S. tax landscape faces potential upheaval, private equity firms must stay vigilant and adaptable. Proactively engaging with tax...more

Allen Barron, Inc.

How to Choose the Right Tax Attorney

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Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...more

BakerHostetler

[Podcast] The Cloakroom with Peter Roskam: Featuring Rep. Darin LaHood, R-IL

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Former Congressman Peter Roskam, who leads BakerHostetler’s Federal Policy team, provides listeners with a front-row seat to the most important policy debates in Congress. In this episode of “The Cloakroom with Peter Roskam,”...more

Williams Mullen

[Event] Winter Tax Forum 2024 - January 31st, Richmond, VA

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Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

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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

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

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Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Bilzin Sumberg

The Draft of the International Tax Overhaul: Where is Captain America?

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On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more

Bilzin Sumberg

IRS Issues Final Downward Attribution Regulations

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On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b)....more

McDermott Will & Schulte

[Event] Tax in the City® - June 3rd, Seattle, WA

We invite you to join us for our Tax in the City®: A Women’s Tax Roundtable in Seattle. We plan to discuss, among other topics, post-TCJA tax treatment of foreign branches (and disregarded entities), new BEAT guidance, an...more

Skadden, Arps, Slate, Meagher & Flom LLP

CARES Act Tax Considerations

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more

McDermott Will & Schulte

[Event] Tax in the City®: A Women's Tax Roundtable - March 12th, Seattle, WA

Mark your calendars for our spring 2020 Tax in the City®: A Women’s Tax Roundtable in Seattle—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Fenwick & West LLP

Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

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On December 2, 2019, Treasury and the IRS released final and proposed regulations on the foreign tax credit. As expected, the final regulations finalize the 2018 proposed regulations relating mainly to the Tax Cuts and Jobs...more

McDermott Will & Schulte

[Event] Tax in the City® A Women's Roundtable - December 5th, Chicago, IL

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We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including: • Judicial deference and potential impact on TCJA audits • Taxation of the digitalized...more

McDermott Will & Schulte

[Event] West Coast Tax Forum: California & Beyond: The Impact Of State, Federal And International Tax Developments On Golden State...

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Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges. Join members...more

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