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The economic substance doctrine in the U.S. has its roots in case law that aimed to deny tax benefits generated from certain abusive transactions entered into solely or primarily to obtain tax benefits.

From time to time in the course of our practice we have encountered and informed clients about developments in matters of international taxation in various non-U.S. jurisdictions.

On January 20, 2025, the White House issued a memorandum, announcing that the "OECD Global Tax Deal" has "no force or effect in the United States" and disavowing "any commitments" previously made by the United States ...

The U.S. continues to captivate global businesses, attracting significant foreign direct investment (FDI). It's easy to understand why: Entering the U.S. market is a strategic move that gives your business access.

The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements.

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017...

As an American, it doesn't matter where you live or work. All your income is taxable by the IRS.

For U.S. tax purposes, gain or loss upon a sale or exchange of property is generally sourced based on the tax home of the seller. For a foreign person investing in a partnership...

On December 20, 2018, the US Department of Treasury and the IRS released proposed regulations under Section 864(c)(8) of the Code on the treatment of a foreign partner's transfer of an interest in a partnership...

On February 17, 2016, the U.S. Treasury Department published a revised model income tax convention (the "New Model Treaty") to replace the prior 2006 version.

Indirect tax obligations are evolving rapidly as governments modernize their rules for the digital economy. If your organization is working across borders...

A U.S. taxpayer that is subject to income tax in both the U.S. and a foreign country can reduce the amount of tax payable to the U.S. by claiming a credit for foreign income taxes paid or accrued...

Cost sharing has been a part of IRS regulations since 1994, but only this summer has the IRS developed an audit program for its international examiners and field specialists.

The document is intended to be used as a starting point for tax treaty negotiations between jurisdictions.

The year 2015 promises to be an active one in U.S. international tax policy.

The Court of Appeal in GE Financial Investments Ltd v HMRC [2024] ruled that "stapling" shares did not make the company a US resident under the UK-US double tax treaty, emphasizing the need for a substantive local connection for tax residency. US nor carrying on a business in the US through a permanent establishment situated there.

International tax reform in 2026 introduced structural changes that affect how global income is classified, included, deducted, and limited.