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On August 10, 2010, the House passed, without change, the Senate’s version of H.R. 1586, sending the bill to President Obama. The President signed the legislation later that day.

On May 4, 2009, President Obama and Treasury Secretary Geithner unveiled two components of the Administration’s plan relating to US international tax reform.

Transferring wealth to a spouse who isn't a U.S. citizen can create complex gift, estate and generation-skipping transfer tax challenges.

On May 20, 2015, the Treasury Department released five proposed changes to the U.S. Model Income Tax Treaty (the U.S. Model).

The US Senate Finance Committee has released a substitute (the "Senate version") for the tax provisions of the "One Big Beautiful Bill," the budget reconciliation bill currently under consideration by Congress.

As countries around the world enact legislation implementing Pillar Two, the Republican majority of the House Ways & Means Committee has made no secret of its dissatisfaction with the Biden Administration's willingness...

We set out below a recap of some of the key European and international tax developments to note at the start of 2019.

For 300 years, the principle known as "the revenue rule" sharply limited collaboration among nations with respect to tax. In the seminal 1729 court decision of Attorney General v. Lutwydge...

The Mutual Agreement Procedure ("MAP") is a useful dispute resolution mechanism for multinational companies facing a transfer pricing...

Under broad regulatory authority contained in section 6039G, the 2009 Notice expands the reporting that is due from covered expatriates in years following the year of expatriation.

One message stood out during our Tax Symposium 2026 session, Tax controversy: What’s hot and what’s not: The Internal Revenue Service (IRS) is becoming more strategic...

Code §59A was enacted to impose tax on U.S. corporations with substantial gross receipts when base erosion payments to related entities significantly reduced regular corporate income tax

Last Tuesday’s midterm election results signaled major changes coming to Capitol Hill in 2015.

In Chief Counsel Advice AM 2025-002 (dated Sept. 8, 2025; released Sept. 19, 2025) (Memorandum), the IRS analyzed how U.S. income tax treaties apply to the branch profits tax...

The United States is no stranger to capital from foreign investors.

On March 25, the Internal Revenue Service issued Notice 2014-21 containing guidance and frequently asked questions relating to virtual currencies such as bitcoins.