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
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
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
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
On May 14, 2025, the House Ways and Means Committee approved the “One, Big, Beautiful Bill,” containing the tax provisions destined for the budget reconciliation package. Several of the bill’s provisions would affect...more
5/16/2025
/ Filing Requirements ,
Government Agencies ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Proposed Legislation ,
Reporting Requirements ,
Tax Reform ,
Tax Returns ,
Ways and Means Committee
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 -
The validity of the 245A DRD for indirectly owned foreign corporations -
On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more
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
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