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Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

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As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Morgan Lewis

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

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The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

ArentFox Schiff

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

ArentFox Schiff on

The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

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

Jones Day

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

Jones Day on

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

Polsinelli

Hydrocarbon Tax Policy Trends

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As governments focus on clean energy and carbon reduction initiatives, their oil and gas taxation policies have increasingly come under scrutiny. Polsinelli’s attorneys review a few overarching themes concerning expected...more

Morrison & Foerster LLP

Global Developments in the Taxation and Reporting of Digital Assets

Just 10 years ago, only your millennial, techie cousin had ever heard of, let alone purchased, any cryptocurrency. Fast forward to 2021, and the volume of cryptocurrency transactions has grown to $15.8 trillion....more

Davies Ward Phillips & Vineberg LLP

Highlights of Canada’s Latest Legislative Tax Proposals

The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax...more

Holland & Knight LLP

The Most Interesting International Tax Proposals in Biden's FY 2023 Budget

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This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage...more

Freeman Law

OECD Proposes Rules for Intermediary Crypto-Asset Reporting, Due Diligence

Freeman Law on

On March 22, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued proposed rules for the collection and exchange of information on transactions involving crypto-assets. The OECD intends for these...more

McDermott Will & Emery

New Attribution Requirement Denies Foreign Tax Credits For Certain Withholding Taxes (And Other Taxes)

McDermott Will & Emery on

On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC) for certain foreign withholding taxes...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Law Struggles To Keep Pace With the Proliferation of Cryptocurrency

Takeaways - The technical architecture of various cryptocurrencies makes it difficult to bring them within existing tax rules, even those designed to deal more generally with the digital marketplace. The U.S., U.K. and...more

Holland & Knight LLP

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

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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

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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

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After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

McGuireWoods LLP

Tax Policy Update

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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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