News & Analysis as of

U.S. Treasury Tax Treaty Tax Rates

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

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

Womble Bond Dickinson

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

Womble Bond Dickinson on

On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more

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