Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
12/26/2025
/ Benefit Plan Sponsors ,
Diverted Profits Tax ,
Employee Benefits ,
Final Rules ,
Foreign Direct Investment ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
One Big Beautiful Bill Act ,
Proposed Rules ,
Tax Credits ,
Tax Legislation ,
Transfer Pricing ,
U.S. Treasury
In furtherance of its efforts to provide guidance related to the implementation of tax law changes that are part of the One Big Beautiful Bill Act of 2025 (OBBBA), on December 4, 2025, the IRS issued Notice 2025-78 (Notice)....more
12/18/2025
/ Cross-Border Transactions ,
Foreign Derived Intangible Income (FDII) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
One Big Beautiful Bill Act ,
Proposed Rules ,
Tax Deductions ,
Tax Legislation ,
Tax Reform ,
U.S. Treasury
In furtherance of its efforts to provide guidance related to the implementation of tax law changes that are part of the One Big Beautiful Bill Act of 2025 (OBBBA), on December 4, 2025, the IRS issued Notice 2025-75 (Notice),...more
12/17/2025
/ Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
One Big Beautiful Bill Act ,
Pro Rata Sharing ,
Reporting Requirements ,
Subpart F ,
Tax Reform ,
Taxation
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
12/12/2025
/ Acquisitions ,
Cross-Border Transactions ,
Final Rules ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Mergers ,
New Guidance ,
OECD ,
One Big Beautiful Bill Act ,
Proposed Regulation ,
Share Buybacks ,
Stock Repurchases ,
Tax Planning ,
Transfer Pricing ,
U.S. Treasury
In furtherance of its efforts to provide guidance related to the implementation of tax law changes that are part of the One Big Beautiful Bill Act of 2025 (OBBBA), on November 25, 2025, the IRS issued Notice 2025-72 (Notice)....more
12/5/2025
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
One Big Beautiful Bill Act ,
Proposed Legislation ,
Proposed Regulation ,
Tax Credits ,
Tax Legislation ,
U.S. Treasury
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
9/4/2025
/ BEPS ,
Cross-Border Transactions ,
Digital Assets ,
FIRPTA ,
Foreign Corporations ,
International Tax Issues ,
IRS ,
New Regulations ,
Proposed Rules ,
Public Comment ,
Real Estate Transactions ,
Reorganizations ,
Taxation ,
U.S. Treasury
On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more
9/3/2025
/ Comment Period ,
Cross-Border Transactions ,
Final Rules ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
OECD ,
Proposed Regulation ,
Tax Liability ,
Tax Reform ,
U.S. Treasury
The President’s Working Group on Digital Asset Markets recently issued a detailed report, titled “Strengthening American Leadership in Digital Financial Technology,” recommending regulatory and legislative proposals to...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On May 22, 2025, the House of Representatives voted along party lines (with one Republican member voting present and two Republican members not voting) to advance the “One Big Beautiful Bill” Act (the OBBB) to the Senate for...more
On May 12, 2025, the House Committee on Ways and Means (WMC) released a draft of the tax provisions of the highly anticipated budget reconciliation bill, referred to as the “One Big Beautiful Bill” Act (OBBB), and on May 14,...more
5/21/2025
/ Foreign Corporations ,
International Tax Issues ,
New Legislation ,
OECD ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Rates ,
Tax Reform ,
U.S. House ,
Ways and Means Committee
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
3/19/2025
/ Corporate Taxes ,
Double Taxation ,
EU ,
Foreign Investment ,
International Tax Issues ,
IRS ,
Proposed Rules ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
Tax developments -
The validity of the 245A DRD for indirectly owned foreign corporations -
On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more
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
On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more
Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more
On December 29, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published Notice 2024-16 (Notice) announcing their intent to issue proposed regulations relating to the determination of...more
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
The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is...more
9/1/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Profits ,
GILTI tax ,
Green Book ,
International Tax Issues ,
OECD ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure:
..Allows controlled...more
5/27/2021
/ Accounting Methods ,
Audits ,
Controlled Foreign Corporations ,
Depreciation ,
Foreign Corporations ,
GAAP ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
Recently released final regulations provide some relief to taxpayers that are subject to high foreign taxes on their global intangible low-taxed income (GILTI), but whether the GILTI high-tax exclusion is beneficial to any...more
Significant provisions of the 2020 Proposed Regulations addressing the application of section 163(j) to foreign corporations and their shareholders include:
..An election under which a controlled foreign corporation (CFC)...more
Final regulations addressing the treatment of certain related-party indebtedness as equity for US federal income tax purposes were released on May 13, 2020. The regulations finalize without material change regulations that...more