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
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
This is the third edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be the significant taxpayer wins and losses and analyzed those results. Our entire...more
12/1/2025
/ Apportionment ,
Corporate Taxes ,
Digital Services Tax ,
False Claims Act (FCA) ,
Franchise Taxes ,
Income Taxes ,
IRS ,
Manufacturers ,
OR Supreme Court ,
PA Supreme Court ,
Property Tax ,
SALT ,
State and Local Government ,
State Taxes ,
Statute of Limitations ,
Tax Appeals ,
Tax Exemptions ,
Taxation