AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
An In-Depth Look at International Tax in Africa: Part 2
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Our Federal & International Tax Group reviews a pair of Tax Court rulings that raise significant questions about the potential formulary and holding period limitations on foreign tax credits available on Section 78 gross-ups...more
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
On March 18, 2026, Rev. Proc. 2026-17 was released, providing relief to taxpayers that made an election under section 163(j)(7) to be treated as an “electing real property trade or business,” “electing farming business,” or...more
This article addresses certain U.S. federal income tax issues for U.S. corporations with Israeli research and development subsidiaries. It focuses on four interconnected issues that create complexity and potential tax...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
The Internal Revenue Service recently updated guidance in Fact Sheet FS-2025-09 (Fact Sheet) to address changes to the limitation on business interest expense deductions under Internal Revenue Code Section 163(j) enacted by...more
The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework) on January 5, 2026, released its Side-by-Side (SbS) Safe Harbor package (SbS Package) to streamline Pillar Two's...more
On January 5, 2026, the Organisation for Economic Co-operation and Development (OECD) released a long-awaited package of administrative guidance which introduces a number of new safe harbors within the Pillar Two Global...more
From evolving cross-border tax rules to new opportunities in global business planning, 2025 brought significant developments affecting individuals, entrepreneurs, and companies operating internationally....more
On December 4, 2025, the United States Internal Revenue Service (IRS) published Notice 2025-75, Notice 2025-77, and Notice 2025-78 providing guidance on certain provisions that were modified as a result of the H.R. 1, P.L....more
The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election under Section 898(c)(2) and modifications to the treatment...more
The United States Internal Revenue Service (IRS) released Notice 2025‑72 (Notice) on November 25, 2025, addressing two issues arising from the repeal of the one‑month deferral election under Section 898(c)(2). Specifically,...more
Subpart F income requires U.S. shareholders of controlled foreign corporations to report certain categories of foreign income — even when no distribution is made. This article explains how Subpart F works, the types of income...more
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 November 25, 2025, the IRS issued Notice 2025-72 (Notice)....more
As with the Tax Cuts and Jobs Act (TCJA) in 2017, the 2025 calendar year ushered in a new set of tax legislation – the One Big Beautiful Bill Act (OBBBA) – as well as several changes the current administration made to the...more
It is axiomatic that a transaction between related businesses – i.e., businesses that are owned or controlled directly or indirectly by the same interests (a “controlled group”) – will generally be subject to heightened...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
The Tenth Circuit recently affirmed the Tax Court’s denial of Liberty Global Inc.’s $240 million foreign tax credit (FTC) claim stemming from the recapture of an overall foreign loss (OFL) triggered by the $3.9 billion sale...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBB) into law, making permanent the reduced individual tax rates and brackets established by the Tax Cuts and Jobs Act of 2017 and modifying a...more
The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more
The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking a significant overhaul of the international tax landscape. This legislation introduces several key changes aimed at refining...more
On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more
On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and...more
As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more