Tax Reform, Compliance, Corporate Taxes

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

Hone Maxwell on 7/30/2025

Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Congress Establishes Permanent Opportunity Zones

Pierce Atwood LLP on 7/11/2025

When Congress enacted the One Big Beautiful Bill Act (the Bill), it permanently established, with some modifications, the federal Opportunity Zone tax incentive program (the OZ Program). Below is a summary of the current OZ...more

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

Skadden, Arps, Slate, Meagher & Flom LLP on 1/23/2025

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

The Organization for Economic Co-Operation And Development (OECD) Global Tax Deal (Global Tax Deal)

Akin Gump Strauss Hauer & Feld LLP on 1/22/2025

Issues a memorandum rejecting U.S. commitments related to the OECD Global Tax Deal unless enacted by Congress. It directs the Treasury and USTR to identify extraterritorial taxes and tax practices disproportionately impacting...more

Navigating the UTPR and ISDS: Implications in the EU

McDermott Will & Schulte on 1/8/2025

The global tax landscape is experiencing a profound transformation as the OECD/G20’s Pillar Two rules are adopted. Among these, the Undertaxed Profits Rule (UTPR) has emerged as a pivotal mechanism designed to ensure that...more

Spring Budget 2024 - Will We See Material Reform?

BCLP on 3/1/2024

Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more

IRS Rules That A Partially Tax-Free Transaction Qualifies As ‘Covered Transaction’ For Purposes Of The Transaction Cost...

Troutman Pepper on 7/17/2013

The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5....more

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