On December 15, 2025, the Treasury and IRS published final and temporary regulations (TD 10042) and proposed regulations (REG-101952-24) under section 892 of the Internal Revenue Code (Code) that will affect how foreign...more
12/19/2025
/ Cross-Border Transactions ,
Debt ,
Final Rules ,
Foreign Governments ,
Foreign Investment ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment Portfolios ,
IRS ,
New Regulations ,
Proposed Rules ,
Safe Harbors ,
Tax Exemptions ,
Tax Planning ,
Taxation ,
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
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
On November 18, 2025, the OECD adopted the “2025 Update to the OECD Model Tax Convention” (Update), which includes broad-ranging updates to the OECD model treaty (Model Treaty).
The most significant updates to the...more
12/4/2025
/ BEPS ,
Cross-Border Transactions ,
Double Taxation ,
Exchange of Information ,
Globalization ,
Home Offices ,
International Tax Issues ,
New Guidance ,
OECD ,
Remote Working ,
Tax Planning ,
Tax Policy ,
Tax Treaty ,
Taxation ,
Transfer Pricing
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
In a favorable development for cryptocurrency investment, the Internal Revenue Service (IRS) issued Revenue Procedure 2025-31. The guidance provides a safe harbor under which certain publicly traded trusts may “stake” their...more
11/18/2025
/ Blockchain ,
Cryptocurrency ,
Digital Assets ,
ETFs ,
Grantor Trusts ,
Income Taxes ,
Investment Funds ,
Investment Trust Companies ,
IRS ,
New Guidance ,
Revenue Procedures ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Tax Planning ,
Taxation ,
Trusts ,
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
10/16/2025
/ Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Investment ,
IRS ,
New Guidance ,
New Legislation ,
Regulatory Agenda ,
Reporting Requirements ,
Tax Planning ,
Trump Administration ,
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
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
On the heels of Executive Order 14178, the President’s Working Group on Digital Asset Markets (Working Group) has released its comprehensive report, “Strengthening American Leadership in Digital Financial Technology” (the...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
6/12/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Cryptoassets ,
Financial Institutions ,
Financial Services Industry ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
IRS ,
OECD ,
Reporting Requirements ,
Tax Credits ,
Tax Cuts and Jobs Act
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 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...more
5/28/2025
/ Business Development ,
Federal Budget ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
New Legislation ,
REIT ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Taxation ,
Ways and Means Committee
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
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (88 FR 59576) that detail the information reporting requirements with respect to brokers of...more
Last week, the Internal Revenue Service (IRS) issued Notice 2022-37, which further extends the phase-in period for compliance with final regulations under sections 871(m), 1441, 1461, and 1473 regarding dividend...more
On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more
8/2/2022
/ C-Corporation ,
Carried Interest ,
Holding Periods ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Tax Cuts and Jobs Act
Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more
Since the announcement was made that the London Interbank Offered Rate (LIBOR) was to be discontinued, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have released three pieces of guidance...more
While the United Kingdom left the European Union (EU) last year, the competent authorities of United States and United Kingdom have agreed that the United Kingdom will remain in the EU for purposes of the US-UK Income Tax...more
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
On July 28, 2020, Treasury and the IRS released highly anticipated final regulations under section 163(j) and related amended regulations under sections 382 and 383 (Final Regulations). This legal alert focuses on provisions...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