News & Analysis as of July 12, 2025

Foreign Derived Intangible Income (FDII)

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Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on 7/8/2025

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on 10/14/2020

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

Burdensome Documentation Requirements Modified under the Final Section 250 Regulations

McDermott Will & Emery on 7/28/2020

The US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have issued highly anticipated guidance (the Final Regulations) regarding the substantiation requirements necessary to claim a section 250...more

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

Womble Bond Dickinson on 8/25/2019

On August 9, 2019, the US Treasury Department published proposed regulations for the classification of “cloud transactions” and “transactions involving digital content” under the source of income rules of the Internal Revenue...more

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Internal Revenue Code (IRC) › Today's Popular Updates › Foreign Derived Intangible Income (FDII)

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

Burdensome Documentation Requirements Modified under the Final Section 250 Regulations

Proposed US Tax Rules for Cloud Computing Transactions and Digital Downloads – International Implications Are a Reason to Review

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