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
7/16/2025
/ Business Taxes ,
Compensation ,
Corporate Taxes ,
Employee Benefits ,
Executive Compensation ,
Federal Budget ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Loper Bright Enterprises v Raimondo ,
New Legislation ,
SCOTUS ,
Tax Court ,
Tax Reform ,
Taxation ,
Trump Administration
On July 2, 2025, the Tax Court issued its unanimous reviewed opinion in JM Assets, LP v. Commissioner, 165 T.C. 1. It held that the Service did not timely issue a final partnership adjustment (FPA) to JM Assets, LP (JM...more
7/11/2025
/ Administrative Authority ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
Loper Bright Enterprises v Raimondo ,
Regulatory Agencies ,
SCOTUS ,
Statutory Interpretation ,
Tax Court ,
Taxation
The booklet summarises key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources.
Key developments:
- US Supreme Court...more
10/3/2024
/ Chevron Deference ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
FBAR ,
Financial Crimes ,
IRS ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
SCOTUS ,
Whistleblower Protection Policies