News & Analysis as of

U.S. Treasury Proposed Rules International Tax Issues

McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

Fenwick & West LLP on

The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

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