News & Analysis as of

International Tax Issues

Barnea Jaffa Lande & Co.

Approval of Minimum Corporate Tax on Multinational Groups Law: Israel Joins the New Global Standard

On December 31, 2025, Israel enacted legislation imposing a minimum corporate tax on multinational groups, which applies to Israeli resident entities that are members of an MNE as of the 2026 tax year....more

Hone Maxwell

FDDEI: Shift Profits to the U.S. and Get a 14% Tax Rate

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Foreign Derived Deduction Eligible Income (FDDEI) allows U.S. domestic C corporations to reduce the effective federal tax rate on qualifying foreign sales and services income to approximately 14%. By properly structuring U.S....more

Herbert Smith Freehills Kramer

UK PLC Insight: Return of B Share Schemes?

Whilst the last couple of years have seen many UK plcs executing share buybacks - to such an extent that during an 18-month period, FTSE 350 issuers bought back £78bn of shares and the FCA published a multi-firm review - 2026...more

Hone Maxwell

The Future of Global Law & Business: Why Cross-Border Clients Need One Trusted Advisor

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Global legal, tax, and business clients don’t lack access to experts — they lack the time, knowledge, and bandwidth to figure out which experts they need, who to trust, and how to manage them all. A single trusted advisor...more

A&O Shearman

Anti-abuse provisions in double tax treaties: beneficial ownership, the EU Danish cases and U.S. limitation on benefits

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In recent years, we have seen tax authorities increasingly relying on anti-abuse arguments to deny relief under double tax treaties. In this briefing, we consider three themes that have been coming up frequently in practice...more

Mayer Brown

US Treasury Issues Final and Proposed Regulations Under Section 892 Affecting Foreign Government Investors

Mayer Brown on

The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations and new proposed regulations under Section 892 of the Code,1 significantly clarifying when foreign governments and their...more

Mayer Brown

TBU | Offset of Taxes Paid Abroad by Controlled and Affiliated Companies – RFB Interpretative Declaratory Act No. 1/2026

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On January 23, 2026, the Brazilian Federal Revenue Service (“RFB”) published Interpretative Declaratory Act (“ADI”) No. 1/2026, which addresses the use of taxes paid abroad by directly or indirectly controlled or affiliated...more

Bilzin Sumberg

Credit Where Credit is Due

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Private clients investing in US-situs assets, such as interests in US real property or stock of a US corporation, take particular care to ensure that their investments are structured in a tax-efficient manner. For many...more

Mayer Brown

Illustration de la qualification d'un siège de direction effective en France pour une société luxembourgeoise

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FAITS ET PROCÉDURE : Une SA de droit luxembourgeois (la « Société »), ayant une activité de société holding, détient des participations dans plusieurs sociétés d’un groupe français exerçant leur activité en France....more

Paul Hastings LLP

Analyzing the Impact of Proposed Section 892 Regulations on Sovereign Wealth Funds and Other Foreign Governmental Investors

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On Dec. 15, 2025, the IRS published proposed regulations under Section 892 of the Internal Revenue Code that provide additional guidance relating to the taxation of foreign government income from investments in the United...more

Conyers

Common Reporting Standard: Cayman Islands Regulatory Update

Conyers on

Effective 1 January 2026, the Cayman Islands will implement extensive revisions to the Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations (the “CRS Regulations”),...more

Fenwick & West LLP

What the OECD’s Pillar Two Side-by-Side Safe Harbor Means for US Multinationals

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The Organisation for Economic Co-operation and Development (OECD) issued a side-by-side package (the package) on January 5, 2026, resolving many of the concerns that U.S.-parented multinational companies had with the Pillar...more

Holland & Knight LLP

Importancia de la emisión y transmisión oportuna de los DSNO a la DIAN

Holland & Knight LLP on

El Documento Soporte en adquisiciones con sujetos no obligados a expedir factura o documento equivalente (DSNO), bien sea nacionales como las personas naturales o proveedores del exterior constituye un requisito fundamental...more

Foodman CPAs & Advisors

Actualizaciones FATCA: Cambios en el Esquema y Preparación para IDES en 2026

El IRS emitió un boletín de FATCA News and Information confirmando que el International Data Exchange Service (IDES) está operativo después de un período de indisponibilidad del sistema....more

Foodman CPAs & Advisors

FATCA Reporting Updates: Schema Changes and IDES Readiness for 2026

The IRS issued a FATCA News and Information bulletin confirming that the International Data Exchange Service (IDES) is operational following a period of system unavailability....more

Hogan Lovells

Luxembourg - New attractive carried interest regime

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On 22 January 2026, the Luxembourg parliament adopted a reform of the carried interest regime (the “Law”)1, aiming at extending its benefits, making it more attractive, and clarifying its tax treatment. This reform2,...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Employee Stranded Abroad? Navigating U.S. Visa Delays and International Remote Work Risks

Some U.S. employers are facing a complicated situation: a foreign national employee on a work visa, such as an H-1B, travels abroad for what should be a short trip, with the goal of renewing the visa stamp travel document,...more

Allen Barron, Inc.

Five Reasons to Choose an Integrated Tax and Accounting Firm

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When it comes to managing your finances, the right firm should offer more than basic bookkeeping or seasonal tax preparation. What are the five reasons to choose an integrated tax and accounting firm?...more

Mayer Brown

UK HMRC Pauses Concession on Failures to Withhold Tax on Interest Payments

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1. WHAT HAPPENED? HM Revenue & Customs (HMRC) has paused operation of its long‑standing practice under which, where UK‑source yearly interest was paid gross to a treaty-entitled overseas lender before HMRC clearance was...more

McDermott Will & Schulte

Global equity plan reporting obligations for calendar-year 2026: Part one

Global equity plans are complex, and their administration requires collaboration across multiple departments, including legal, human resources, payroll, and tax....more

Proskauer - Tax Talks

Treasury and the IRS Release Final and Proposed Regulations on Section 892

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On December 15, 2025, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations (the “Final Regulations”) and proposed regulations (the “Proposed Regulations”)...more

Mayer Brown

OECD Pillar Two Side-by-Side System and New Safe Harbors

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On January 5, 2026, the Organisation for Economic Co-operation and Development (“OECD”) announced that the Inclusive Framework on Base Erosion and Profit Shifting agreed to a new package of administrative guidance (the...more

A&O Shearman

Italy’s 2026 Budget Law: practical takeaways for businesses

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The 2026 Italian Budget Law was published in the Italian Official Gazette on December 31, 2025. It introduces significant changes to Italy’s tax framework with material implications for investors, financial intermediaries,...more

Holland & Knight LLP

Revisión del Régimen Presencia Económica Significativa en Colombia

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Tradicionalmente, conforme a lo dispuesto en los artículos 24 y 408 del Estatuto Tributario (ET), en materia de servicios, solo se consideran ingresos de fuente nacional aquellos derivados de los que son prestados en...more

Holland & Knight LLP

OECD Pillar Two Side-by-Side Safe Harbor Package: Technical Review and Implications

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The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework) on January 5, 2026, released its Side-by-Side (SbS) Safe Harbor package (SbS Package) to streamline Pillar Two's...more

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