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H. David Rosenbloom contributes an essay examining United States income tax treaties as part of a commemorative publication honoring Kees van Raad's nearly five decades of teaching international tax law. The essay explores the defense and significance of U.S. tax treaty policy within the broader context of international taxation.

On August 10, 2010, President Obama signed the Education Jobs and Medicaid Assistance Act of 2010 into law.

There is a revolution underway in the world of international taxation.

Retaliatory tax provisions contained in H.R. 1, the "One Big Beautiful Bill Act" that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions, including US operations of foreign multinational groups and inbound investments.

In this edition: the U.S. Court of Appeals for the Eighth Circuit remands the Medtronic case back to the Tax Court ...

As we settle into the new year, let's take a moment to first consider last year's tax developments and then take a look ahead to what 2023 might have in store for us.

Earlier this month, we published a briefing summarising the 'retaliatory' tax measures in the 'One Big Beautiful Bill Act' Bill (the "Bill"), which target certain overseas taxpayers...

A federal court has vacated IRS Notice 2025-42, which eliminated the Five Percent Safe Harbor for establishing "beginning of construction" for wind and solar projects seeking federal clean energy tax credits. With less than a month before the July 4, 2026 statutory deadline and an expected appeal, developers face critical decisions about whether to rely on the restored safe harbor or continue with existing compliance strategies under uncertainty.

When a U.S. company acquires foreign targets, the use of a holding company structure abroad may provide certain global tax benefits.

The proposed regulations would alter the basis for taxing compensatory partnership interests, while attempting to preserve the tax consequences under the current rules.

The cost of being a US citizen living abroad extends well beyond going through the motions of staying US tax compliant annually. It includes legal/accounting fees, huge failure-to-file penalties if late...

Hybrid mismatch arrangements can be used to achieve double non-taxation including long-term deferral.

On October 8, 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) announced that 136 countries have agreed on a two-pillar framework that would dramatically alter the taxation of multinational enterprises (MNEs).

The U.S. Court of Appeals for the Fifth Circuit has ruled that illicit payments made by a U.S. company to foreign customs officials to reduce the company’s tax and customs burdens may, under the right circumstances, violate the U.S. Foreign Corrupt Practices Act (the "FCPA"). The court’s reasoning in <I>U.S. v. Kay </I>has far-reaching implications, and will force many U.S. companies to rethink and scrutinize how their marketing staffs interact with foreign&nbs

Traditionally, taxing jurisdiction has developed on a country-by-country basis.

The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework)...

The United States was initially reluctant to adopt the recommendations of the base erosion and profit shifting (BEPS) initiative spearheaded by the OECD and the G20 group of nations.

FATCA was passed in 2010 and is aimed at addressing tax evasion by U.S. taxpayers with investments in offshore accounts.