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
The section 987 regulations that were finalized in 2024 after decades of revision are getting yet another makeover. On February 25, 2026, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued...more
3/4/2026
/ Business Taxes ,
CFCs ,
Comment Period ,
Controlled Foreign Corporations ,
Cross-Border Transactions ,
Currency Exchange ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
Proposed Regulation ,
Regulatory Agenda ,
Tax Reform ,
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
12/26/2025
/ 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
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 -
Other countries’ response to United States position on the Global Tax Deal -
On Friday, President Trump issued a memo discussing his administration’s intent to defend US companies from unfair foreign...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
On November 17, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) relating to eligible energy property that qualifies for the section 48...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
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
7/13/2023
/ Comment Period ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Proposed Regulation ,
Public Hearing ,
Renewable Energy ,
Semiconductors ,
Tax Credits ,
Tax Exempt Entities ,
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
On April 4, 2023, the IRS and the Department of Treasury released Notice 2023-29 (the Notice), which provides that proposed regulations are forthcoming regarding the energy community bonus tax credits under IRC sections 45,...more
On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (Service) issued Notice 2023-17 (Notice), establishing the 48(e) Low-Income Communities Bonus Credit Program (Program) with respect...more
3/13/2023
/ Community Development ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Guidance ,
Solar Energy ,
Tribal Lands ,
U.S. Treasury ,
Wind Power
On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued Notice 2023-18 (Notice), which establishes the program to allocate $10 billion of tax credits that were added by the...more
2/17/2023
/ Biden Administration ,
Clean Energy ,
Climate Change ,
Energy Projects ,
Energy Tax Incentives ,
Inflation Reduction Act (IRA) ,
Investment Tax Credits ,
IRS ,
Manufacturers ,
Production Tax Credit ,
Renewable Energy ,
U.S. Treasury
On December 19, 2022, Treasury announced a timeline for releasing information on certain tax provisions of the Inflation Reduction Act (IRA). As set forth in the announcement, Treasury will provide the following information...more
The Tax Court issued its second opinion in Medtronic following a remand by the US Court of Appeals for the Eighth Circuit (Medtronic, Inc. v. Comm’r, 900 F.3d 610 (8th Cir. 2018)) of its earlier decision. In that...more
8/25/2022
/ IP License ,
IRS ,
License Agreements ,
Medtronic ,
Patent Litigation ,
Patents ,
Puerto Rico ,
Royalties ,
Siemens ,
Subsidiaries ,
Tax Court ,
Transfer Pricing
On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the Budget) followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals....more
On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House...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
On Monday, August 9, the Senate released the framework for the Fiscal Year 2022 Budget Resolution Agreement, and subsequently passed the resolution in a 50-49 partisan vote on August 10. The resolution now goes to the House,...more
Fresh from their July 4 recess, the Senate has returned to Washington to continue infrastructure and budget bill negotiations. As previously discussed, there are two distinct legislative paths making their way through...more
As Congress and the White House look to make a deal on infrastructure by this summer, negotiations regarding changes in the tax law continue. Since our prior alert, while progress has been made regarding a bipartisan...more
7/8/2021
/ Biden Administration ,
Budget Reconciliation ,
Congressional Committees ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
International Tax Issues ,
OECD ,
Proposed Legislation ,
Reconciliation ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform
Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
7/6/2021
/ Affiliates ,
Business Profits ,
Foreign Profits ,
IRS ,
Medical Devices ,
Medtronic ,
Multinationals ,
Parent Corporation ,
Popular ,
Puerto Rico ,
Tax Court ,
Transfer Pricing
In a US District Court complaint filed May 26, 2021, a married couple is seeking a refund of taxes they paid on cryptocurrency tokens the husband created, asserting that current law does not permit the treatment of created...more
6/23/2021
/ Asset Tokens ,
Blockchain ,
Coinbase ,
Cryptocurrency ,
Data Mining ,
Distributed Ledger Technology (DLT) ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Personal Property ,
Popular ,
Reporting Requirements ,
Tax Refunds ,
Token Sales