News & Analysis as of

International Tax Issues Internal Revenue Service New Guidance

Skadden, Arps, Slate, Meagher & Flom LLP

Executive and Administrative Changes Shape Tax Policy Ahead of Legislation - The Trump Administration’s First 100 Days

The Trump administration has declared that prior U.S. commitments under the OECD’s Pillar Two agreement would have no domestic effect unless approved by Congress, reflecting long-standing opposition....more

BakerHostetler

Global Tax Enforcement Group Provides NFT Red Flag Guidance

BakerHostetler on

Key Takeaways - ..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more

McDermott Will & Emery

IRS Issues Transition Tax Compliance Campaign

McDermott Will & Emery on

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more

Proskauer - Tax Talks

LIBOR Transition: U.S. Tax Guidance From the IRS

Proskauer - Tax Talks on

The U.S. tax authorities have issued substantial guidance related to the phase-out of LIBOR – relevant to lenders, borrowers and parties to financial instruments of virtually every type. In proposed regulations (“the...more

Jones Day

U.S. Treasury Releases Proposed FIRPTA Regulations

Jones Day on

New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more

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