News & Analysis as of

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

Latham & Watkins LLP

One Big Beautiful Bill Introduces Major Changes to Federal Tax Law

Latham & Watkins LLP on

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

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

Frost Brown Todd

Top 10 Biggest Business Tax Breaks (and Hits) in the One Big Beautiful Bill Act

Frost Brown Todd on

With a name like the One Big Beautiful Bill Act (OBBBA), you know two things right away: (1) it’s a mouthful, and (2) you’re going to have to wade through a lot to find the useful parts. Fortunately, two tax lawyers already...more

Vinson & Elkins LLP

One Big Beautiful Bill Act: Key Tax Impacts for Businesses

Vinson & Elkins LLP on

On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance...more

Nutter McClennen & Fish LLP

Breaking Down the “One, Big, Beautiful” Tax Bill: Take One

On May 12, the Republican majority leadership in the House of Representatives released for consideration its tax and spending reconciliation legislation, called the “One Big, Beautiful Bill” (the “Bill”). This major piece of...more

Miller Nash LLP

Today in Tax: Eligibility of Electronic Services Income for FDII Deduction

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

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

McDermott Will & Schulte

Government Releases Final Regulations on FDII and GILTI Deduction

On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York State Responds to Federal Tax Reform

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

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