The U.S. has long been an attractive parent-company jurisdiction for multinational enterprises for a variety of non-tax reasons. At the same time, until recently the U.S. was a relatively unattractive parent-company...more
4/8/2026
/ Business Entities ,
Controlled Foreign Corporations ,
Corporate Restructuring ,
Corporate Taxes ,
Cross-Border Transactions ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Merger Agreements ,
OECD ,
One Big Beautiful Bill Act ,
Reorganizations ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform
On December 12, 2025, Treasury released final regulations (the Final Regulations), as well as proposed regulations (the Proposed Regulations), relating to the Section 892 tax exemption for certain income of foreign...more
12/18/2025
/ Cross-Border Transactions ,
Final Rules ,
Foreign Governments ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investment ,
IRS ,
New Regulations ,
Partnership Interests ,
Partnerships ,
Proposed Rules ,
Real Estate Investments ,
Tax Exemptions ,
Treasury Regulations ,
U.S. Treasury
On October 21, 2025, the Treasury Department published proposed regulations under the Foreign Investment in Real Property Tax Act (FIRPTA) that would repeal the controversial “look-through” rule adopted in final regulations...more
10/29/2025
/ C-Corporation ,
Domestic Corporations ,
FIRPTA ,
Foreign Investment ,
Proposed Regulation ,
Real Estate Investments ,
Regulatory Reform ,
REIT ,
Tax Exemptions ,
Taxation ,
U.S. Treasury
On July 4, 2025, President Donald Trump signed into law the Act (formerly referred to as the One Big Beautiful Bill Act, or OBBBA). The Act includes a suite of tax-related provisions that (1) make permanent many of the...more
7/16/2025
/ Clean Energy ,
Corporate Taxes ,
Employee Benefits ,
Federal Budget ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
International Tax Issues ,
Tax Credits ,
Tax Deductions ,
Tax Incentives ,
Tax Legislation ,
Tax Reform
On June 16, 2025, the Senate Finance Committee released its version of the tax-related proposals (Senate Bill) for inclusion in the One Big Beautiful Bill Act (OBBBA). In line with the bill the House passed on May 22, 2025...more
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
6/27/2025
/ Corporate Taxes ,
Energy Sector ,
Estate Planning ,
Estate Tax ,
International Tax Issues ,
New Legislation ,
Renewable Energy ,
SALT ,
State Taxes ,
Tax Credits ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Key Points -
- The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent.
- The bill...more
6/26/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Corporate Taxes ,
EBITDA ,
Energy Sector ,
Federal Budget ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Proposed Legislation ,
SALT ,
Senate Finance Committee ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Taxation
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
5/29/2025
/ Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Federal Budget ,
Gift Tax ,
GILTI tax ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Local Taxes ,
New Legislation ,
Popular ,
SALT ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Taxation
President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more
3/18/2025
/ Department of Government Efficiency (DOGE) ,
Executive Orders ,
Government Agencies ,
Internal Revenue Code (IRC) ,
International Trade ,
IRS ,
National Security ,
Reciprocity Rules ,
Regulatory Agenda ,
Regulatory Reform ,
Tariffs ,
Tax Liability ,
Tax Planning ,
Trump Administration ,
U.S. Treasury
As Trump administration directives emerge, it’s crucial for businesses and other stakeholders to stay informed and adapt their strategies accordingly. We will provide ongoing coverage of these developments and their potential...more
2/4/2025
/ Affirmative Action ,
Artificial Intelligence ,
Climate Change ,
Cybersecurity ,
Diversity and Inclusion Standards (D&I) ,
Energy Sector ,
Environmental Social & Governance (ESG) ,
Executive Orders ,
Federal Contractors ,
Financial Regulatory Reform ,
Healthcare ,
Intellectual Property Protection ,
International Litigation ,
International Trade ,
Legislative Agendas ,
Life Sciences ,
National Security ,
New Legislation ,
New Regulations ,
OECD ,
Privacy Laws ,
Regulatory Agenda ,
Technology Sector ,
Trade Policy ,
Trump Administration
Since assuming office on January 20, 2025, President Donald Trump has prioritized tax policy, issuing a series of directives aimed at boosting economic growth and advancing the “America First” agenda.
On his first day in...more
1/30/2025
/ Corporate Taxes ,
Energy Projects ,
Energy Sector ,
Executive Orders ,
Green Energy ,
International Tax Issues ,
IRS ,
OECD ,
Regulatory Agenda ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more
In Moore v. United States, the U.S. Supreme Court rejected a constitutional challenge to the Mandatory Repatriation Tax (MRT), holding that the MRT does tax income — the realized earnings of foreign corporations — and thus is...more
On May 1, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released Revenue Procedure 2024-24 (Revenue Procedure), which sets out substantially revised guidelines for private letter ruling (PLR)...more
On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more
4/18/2024
/ Acquisitions ,
Capital Markets ,
Corporate Governance ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
International Tax Issues ,
IRS ,
Mergers ,
Private Equity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Share Buybacks ,
Stock Repurchases ,
Tax Liability ,
U.S. Treasury
On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more
A substantial number of U.S. and overseas corporations have legacy liabilities that are complicating their equity outlook due to their uncertainty and duration. Typical examples are liabilities derived from asbestos-related...more
This edition of Skadden’s quarterly Insights looks at the rising number of de-SPACed companies seeking Chapter 11 protection, the growth of a market designed to assume legacy liabilities, an effort to establish...more
4/20/2023
/ Acquisitions ,
Antitrust Division ,
Artificial Intelligence ,
Banking Sector ,
Capital Markets ,
Chapter 11 ,
Commercial Bankruptcy ,
Corporate Governance ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Energy Tax Incentives ,
Federal Trade Commission (FTC) ,
Holding Companies ,
Inflation Reduction Act (IRA) ,
Innovative Technology ,
Intellectual Property Protection ,
Inventions ,
Liability ,
Mergers ,
Patents ,
Self-Disclosure Requirements ,
Special Purpose Acquisition Companies (SPACs) ,
Tax Credits
On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more
3/20/2023
/ Biden Administration ,
Corporate Taxes ,
Estate Tax ,
Federal Budget ,
Gift Tax ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Issues ,
Partnerships ,
Property Tax ,
Retirement ,
Tax Reform ,
U.S. Treasury
On December 28, 2022, the Treasury Department released a set of proposed regulations that, if finalized, would alter key rules affecting many real estate funds, sovereign wealth funds and other foreign investors in U.S. real...more
Key Points - The first half of 2022 experienced a slowdown in SPAC activity when compared to recent years. Only 77 de-SPAC M&A deals were announced in the first half of 2022, compared to 167 de-SPAC transactions in the same...more
On August 7, 2022, the Senate passed the Inflation Reduction Act (the Act), which is expected to have a significant impact on climate, tax and health care policy in the United States. The result of intense negotiations among...more
In legislative text released October 28, 2021, the House Rules Committee proposed to impose a 1% excise tax on stock repurchases by publicly traded companies starting in 2022. If the provision is enacted, corporations will...more
On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more
6/15/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Energy Tax Incentives ,
GILTI tax ,
Green Book ,
Income Taxes ,
International Tax Issues ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
Former Vice President Joseph Biden has proposed a number of fundamental changes to the tax code over the course of his campaign. If he is elected president and if the Democrats keep control of the House of Representatives and...more
9/24/2020
/ Alternative Minimum Tax ,
Capital Gains ,
Capital Gains Tax ,
Corporate Taxes ,
Estate Tax ,
GILTI tax ,
Joe Biden ,
Like Kind Exchanges ,
Offshore Funds ,
Presidential Elections ,
Retirement Plan ,
Social Security Taxes ,
Tax Credits ,
Tax Policy ,
Tax Rates ,
Tax-Deferred Exchanges