Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more
Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more
Corporate tax proposals in support of President Biden’s ambitious infrastructure plans would raise some $2 trillion over 15 years. Tighter international tax net would apply to corporations operating in low-tax...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 30, 2020 – December 4, 2020... November 30, 2020: After releasing a pre-publication...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 26, 2020 – October 30, 2020... October 26, 2020: The IRS released Rev. Proc. 2020-45...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of...more
Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more
On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more
The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27 – May 31, 2019. May 28, 2019: The IRS released Announcement 2019-05 listing recent...more
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
Our International Tax Group reflects on a few concerns that have cropped up in the wake of the Tax Cuts and Jobs Act and deciphers the government’s responses....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8 – 12, 2019. April 8, 2019: The IRS issued a news release warning taxpayers against...more
US Treasury has now published detailed guidance on a significant US corporate tax rate benefit for any US company that conducts direct sales of property and/or services to foreign persons for foreign use. The tax rate benefit...more
The IRS and Treasury’s proposed regulations on the Section 250 deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) tackle several questions left unanswered by the 2017 tax...more
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section 250, which permits...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4 – 8, 2019....more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more
According to Carol Tan of the IRS, proposed regulations for the international provisions of the GOP tax law will be complete before the end of the year. In order for final regulations to be retroactively applicable starting...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more