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U.S. Treasury Organization for Economic Co-operation and Development

Cooley LLP

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

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On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

Hogan Lovells

Update: US retaliatory taxes to be abandoned following G7 agreement on Pillar Two

Hogan Lovells on

The United States has agreed with other G7 members to remove the section 899 protective tax measures from One Big Beautiful Bill in exchange for an agreement to exclude U.S. headed groups from major aspects of the OECD global...more

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

Holland & Knight LLP on

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

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Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

Holland & Knight LLP

Another Surprise in the One Big Beautiful Bill: Excise Tax on Remittances

Holland & Knight LLP on

As Republicans in the U.S. Senate now consider the reconciliation bill, they will need to consider what tax provisions contained in the One Big Beautiful Bill (OBBB), passed by the U.S. House of Representatives on May 22,...more

Mayer Brown

Congress Proposes a ‘Big Stick’ to Target Discriminatory Tax Measures

Mayer Brown on

At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of February 24, 2025

Tax developments - Other countries’ response to United States position on the Global Tax Deal - On Friday, President Trump issued a memo discussing his administration’s intent to defend US companies from unfair foreign...more

Cadwalader, Wickersham & Taft LLP

Trump Administration 2.0—The First Executive Orders

Within the first month of President Trump’s second term, the nation has witnessed several executive actions relating to tax and tax administration that affect American businesses and consumers. This article summarizes some of...more

Katten Muchin Rosenman LLP

Will Pillar Two Crumble Before It's Built?

Over 135 jurisdictions signed up for a global Organisation for Economic Cooperation and Development (OECD) project in October 2021 aimed at reforming the international taxation system. A Two-Pillar approach was developed to...more

Holland & Knight LLP

A Look at President Trump's America First Trade Policy Executive Order and International Tax

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On his first day in office, among the numerous Executive Orders (EO) released, President Donald Trump announced the America First Trade Policy EO designed to prioritize American interests in international trade and tax and,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax: Trump Exits Global Tax Deal and Freezes Green Energy Funds

Since assuming office on January 20, 2025, President Donald Trump has prioritized tax policy, issuing a series of directives aimed at boosting economic growth and advancing the “America First” agenda. On his first day in...more

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

A&O Shearman

Trump and House Republicans take aim at the global minimum tax and domestic tax measures

A&O Shearman on

Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere. On 20 January, President Trump...more

Proskauer - Tax Talks

Trump Administration Disavows the OECD Global Tax Deal

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On January 20, 2025, the White House issued a memorandum (the “Memorandum”), announcing that the “Organization for Economic Co-operation and Development (OECD) Global Tax Deal” (the “Global Tax Deal”) has “no force or effect...more

Akin Gump Strauss Hauer & Feld LLP

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

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

Morgan Lewis

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

Morgan Lewis on

The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

Eversheds Sutherland (US) LLP

Doubling up: Proposed regulations address interaction of dual consolidated loss rules and GloBE Model Rules, disregarded payment...

Proposed regulations addressing the application of the section 1503(d) “dual consolidated loss” or “DCL” rules were published by the Internal Revenue Service and Treasury on August 7, 2024 (Proposed Regulations). The Proposed...more

Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

Jones Day

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

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In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

BakerHostetler

White House Outlines Key Action Items Based on EO Reports Addressing Digital Assets

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On Sept. 16, 2022, the White House released a Fact Sheet providing key findings and action items arising from the nine reports addressing digital assets that have been submitted to the president to date consistent with the...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

McDermott Will & Emery

New Attribution Requirement Denies Foreign Tax Credits For Certain Withholding Taxes (And Other Taxes)

McDermott Will & Emery on

On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

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In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more

Lowenstein Sandler LLP

Trade Matters - August 2021

1. Biden Administration Trade Posture- The Biden administration is slowly and steadily reviewing the decisions of the Trump administration. So far, the administration has struck a deal with the EU to end the 17-year-old...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and International Tax Changes

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A previous Holland & Knight alert provided an overview of corporate and individual income tax increases as detailed in the U.S. Department of the Treasury May 2021 "Green Book." (See "Biden Administration's FY 2022 Budget and...more

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