On January 16, 2026, the Fifth Circuit decided Sirius Solutions, L.L.L.P. v. Commissioner, which vacated a prior decision of the Tax Court that had denied limited partners in a state law limited partnership the benefit of the...more
2/12/2026
/ Appeals ,
Appellate Courts ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Partnerships ,
Partnership Agreements ,
Partnerships ,
Pass-Through Entities ,
Self-Employment Tax ,
Statutory Interpretation ,
Tax Court ,
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
1/15/2026
/ BEPS ,
Cross-Border Transactions ,
Customs ,
Customs and Border Protection ,
Customs Valuation ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
International Trade ,
IRS ,
New Guidance ,
New Regulations ,
OECD ,
Pillar 2 ,
Tariffs ,
Tax Litigation ,
Tax Reform ,
Transfer Pricing ,
USPS
On January 5, 2026, the OECD published the Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package (side-by-side package), following months of negotiations. The side-by-side package extends and introduces new...more
1/13/2026
/ BEPS ,
Corporate Taxes ,
Cross-Border Transactions ,
Income Taxes ,
International Tax Issues ,
New Guidance ,
New Regulations ,
OECD ,
Pillar 2 ,
Regulatory Requirements ,
Reporting Requirements ,
Safe Harbors ,
Tax Planning ,
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
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
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
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
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
On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued guidance on several topics related to tax credit monetization under the Inflation Reduction Act of 2022 (IRA),...more
7/3/2023
/ Energy Projects ,
Energy Sector ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Production Tax Credit ,
Proposed Regulation ,
Renewable Energy ,
Tax Credits ,
Transfer of Interest ,
U.S. Treasury
On June 14, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released a package of much-awaited guidance (the Guidance) consisting of (i) proposed regulations addressing the tax credit...more
6/19/2023
/ Comment Period ,
Energy Sector ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
IRS ,
Manufacturers ,
Monetization ,
New Guidance ,
Registration Requirement ,
Semiconductors ,
Tax Credits ,
Technology Sector ,
Transfer of Interest ,
U.S. Treasury
Beginning July 12, 2023, the European Commission (Commission) may begin “ex officio” investigations of financial contributions that companies receive from non-EU governments. The Commission may request information or conduct...more
5/12/2023
/ Compliance Dates ,
Countervailing Duties ,
Disclosure Requirements ,
EU ,
European Commission ,
Foreign Subsidies ,
Government Investigations ,
Multinationals ,
New Guidance ,
State Aid ,
Unfair Competition ,
WTO
On March 31, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Proposed Regulations (REG-120080-22) under section 30D of the Internal Revenue Code (Code), the Clean Vehicle Credit,...more
On March 27, 2023, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued much anticipated proposed regulations, REG-105954-22 (Proposed Regulations), and additional guidance in the form of Revenue...more