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At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules...

In early April, Bloomberg News reported on coordinated tax raids on three separate offices of Credit Suisse.

The United States has for many years taxed certain U.S. shareholders of closely held or controlled foreign corporations deriving principally passive or related-party income on their pro rata share of the corporation's earnings whether or not distributed.

The U.S. Treasury and IRS have issued proposed regulations addressing a new category of income excluded from deduction eligible income under section 250(b)(3)(A)(i)(VII), which was introduced by the One Big Beautiful Bill Act. These regulations clarify how income from sales of intangible property and certain depreciable assets will be treated under the foreign-derived deduction eligible income regime, with significant implications for software transactions and related party transfers.

In recent years, we have seen tax authorities increasingly relying on anti-abuse arguments to deny relief under double tax treaties.

The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU Directives relating to the disclosure of tax information known as DAC6 and DAC2.

Remote work is one of COVID-19's enduring legacies. What began as something necessary for health and safety has become a fairly conventional practice.

Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers.

Income tax treaties are designed, among other things, to prevent (or at least reduce) double taxation by allocating taxing jurisdiction between the two countries.

This article covers recent tax developments in Canada, Chile, Mexico and The United States.

Tax partner Kat Gregor and tax counsel Elizabeth Julia Smith published a chapter in the International Comparative Legal Guide – Corporate Tax 2021 entitled...

Congress enacted the N.I.I.T. in 2012 as part of a 2010 law amending the Affordable Care Act ("A.C.A."), more popularly known as "Obamacare." Its creation corresponded to a 0.9% increase...

In this edition of TaxAlert, Ms. Katz summarizes a number of international tax matters, Mr. Doran discusses deferred compensation, and Mr. Rizek discusses tax shelter reform.

On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion...

The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex