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Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

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

Holland & Knight LLP

Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy

Holland & Knight LLP on

By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more

Foley & Lardner LLP

US Senate Approves Protocols to Various Tax Treaties

Foley & Lardner LLP on

On July 16 and 17, 2019, the U.S. Senate approved resolutions of ratification of protocols to amend existing income tax treaties between the United States and various countries, including Spain, Japan, and Switzerland. Before...more

Eversheds Sutherland (US) LLP

LB&I announces new campaigns – Related-party service companies, offshore private banking and loose-filed Forms 5471

On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more

McGuireWoods LLP

Tax Policy Update

McGuireWoods LLP on

NUMBER OF THE WEEK: 10 percent. Rate of the one-time deemed repatriation tax on U.S. multinationals’ foreign earnings under GOP presidential candidate Donald Trump’s tax plan released Sept. 28. The revenue raised through...more

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