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Withholding Tax Digital Services Tax

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...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

Eversheds Sutherland (US) LLP

First to finish: UN approves Article 12B for taxation of automated digital services

While much of the focus has remained on the efforts of the Organisation for Economic Cooperation and Development (OECD) with respect to digital taxation, the United Nations (UN) has finalized revisions to the UN Model Double...more

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