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On June 16, 2025, the Senate Finance Committee released its version of a tax bill, containing new proposed Section 899 of the Internal Revenue Code (which is similar to a provision approved in the earlier House tax bill).

In light of the recent article published by 9fin regarding the adverse implications to U.S. collateralized loan obligations ("CLOs") that resulted from U.K. withholding taxes imposed with respect to a certain dividend financing loan issued by the CFC Group, ...

The Treasury also proposed new regulations that introduce a limited safe harbor for loan origination activities (the 2025 Proposed Regulations).

Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively.

COVID-19 has caused global consternation for many reasons, including the fact that the rapid global shutdown of travel and imposition of lock-downs and other restrictions has stranded travelers

U.S. District Court rules in company’s favor and determines all members of a controlled group of corporations should be treated as a single taxpayer when calculating research credits.

As we predicted, the struggle over taxation of indirect foreign investment in India is not at an end. See Milbank Client Alert, February 23, 2012.

The U.S. has issued an announcement with guidance on how the 2009 amendment to the tax treaty between the U.S. and Switzerland applies to pension and retirement arrangements of both countries.

The One Big Beautiful Bill Act, a budget reconciliation bill, passed the United States House of Representatives vote on May 22, 2025, and is currently under Senate consideration.

It may be time to take a fresh look at the Limitation on Benefits article in U.S. income tax treaties.

The US Court of Federal Claims recently addressed a critical question for Canadian exempt organizations earning US-source income: can they rely on fiscal transparency rules to claim treaty benefits through investment vehicles? The court's ruling in The South Saskatchewan Community Foundation Inc. v. United States examines when charitable organizations may look through intermediary entities to access tax exemptions under the US-Canada tax treaty, with significant implications for cross-border investment

Inbound investment structures seeking to acquire a German or UK corporation should take into account the potential taxation of both the local entity and the shareholder.

On October 31, 2018, the US Internal Revenue Service ("IRS") released proposed regulations ("Proposed Regulations") that, if finalized, may substantially impact the way in which multinational corporations finance their operations.

During the course of 2020, the U.K. government has pushed ahead with introducing new measures that are likely to be of material relevance to financial

FATCA went into effect on July 1, 2014, after numerous delays and multiple rounds of administrative guidance.

The U.S. Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") on February 8, 2012 issued proposed regulations addressing the implementation of the Foreign Account Tax Compliance Act ("FATCA," which was enacted as part of the Hiring Incentives to Restore Employment Act on March 18, 2010).

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles.