Are You a Foreign Agent? [More with McGlinchey, Ep. 21
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 12, 2025 – January 12, 2026....more
On December 15, 2025, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations and proposed regulations under Section 892 of the Internal Revenue Code relating to the taxation of...more
On December 15, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service published new proposed regulations (the “Proposed Regulations”) under Section 8921, which contains the tax exemption for...more
On December 12, the Treasury Department issued final Treasury Regulations (the “Final Regulations”) and proposed Treasury Regulations (the “Proposed Regulations”) that address various issues under Section 892 of the Internal...more
The Internal Revenue Service (IRS) and the U.S. Treasury Department last Friday released final and proposed regulations addressing various rules under section 892. The rules are a mixed bag – some are favourable and provide...more
On December 12, 2025, the United States Department of the Treasury (“Treasury”) and the Internal Revenue Service released final regulations (the “Final Regulations”) under Section 892 of the Internal Revenue Code of 1986, as...more
On December 15, 2025, the Treasury and IRS published final and temporary regulations (TD 10042) and proposed regulations (REG-101952-24) under section 892 of the Internal Revenue Code (Code) that will affect how foreign...more
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
On December 15, 2025, the U.S. Treasury Department (the “Treasury”) and the Internal Revenue Service (IRS) issued final regulations under section 892 of the Internal Revenue Code of 1986, as amended (the “Code,” and such...more
On December 12, 2025, the United States Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (REG-101952-24) under Section 892 of the Internal Revenue Code of 1986, as amended (the...more
On Dec. 12, the Treasury Department and the IRS issued final regulations (the Final Regulations) relating to the taxation of income of foreign governments from investments in the United States under Section 892 of the U.S....more
With a December 8 deadline to come into compliance with the FCC’s new sponsorship identification requirements for airing content connected to a foreign government, broadcasters have been racing to figure out how to comply in...more
On December 5, 2025, the Federal Communications Commission (FCC) issued a Public Notice further delaying the deadline by which broadcasters must comply with the expanded rules concerning the identification of foreign...more
As described in more detail below, by October 10, 2025, all radio and television broadcast stations, both commercial and noncommercial, must prepare a list of important issues facing their communities of license and the...more
On August 21 2025, the Chairman of the Federal Trade Commission (FTC Chairman) sent letters to more than a dozen major U.S. tech companies including cloud computing, data security and social media companies. The template...more
On 4 June 2025, the European Data Protection Board published guidelines clarifying how EU-based companies should assess requests from foreign authorities for access to EU personal data. The EDPB emphasizes that such requests...more
On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more
On June 10, 2025, the Media Bureau of the Federal Communications Commission (FCC or Commission) issued a Public Notice (Notice) announcing that broadcasters have until December 8, 2025 to comply with the FCC’s expanded rules...more
U.S. sanctions are a powerful tool used to influence the behavior of foreign governments, individuals, and entities. Placement on any sanctions watchlist maintained by a regulatory agency can have devastating financial,...more
On July 1, 2025, the United Kingdom’s new Foreign Influence Registration Scheme (FIRS) will formally take effect, creating sweeping registration obligations under U.K. law for persons engaging in certain activities on behalf...more
Alabama and Oklahoma have become the latest states to ban from state-owned devices and networks certain AI tools with links to foreign governments. ...more
Key Takeaways: The U.S. Supreme Court unanimously held that a party cannot establish the U.S. commercial nexus required to invoke the FSIA’s expropriation exception by alleging a foreign state expropriated property in...more
Last week, the Supreme Court issued a unanimous decision in Republic of Hungary v. Simon, a case concerning the scope of immunity under the Foreign Sovereign Immunities Act’s (FSIA) expropriation exception....more
On February 19, 2025, the Committee on Oversight and Government Reform – specifically, Rep. Virginia Foxx and Committee Chairman James Comer – sent a letter to the U.S. Department of Education (DOE) Acting Secretary, Denise...more
Corporate compliance officers might feel like they’ve been put through the whirlwind lately, with the Trump Administration issuing one sweeping announcement about corporate enforcement after another. Except, remember what a...more