Share on LinkedInShare on LinkedIn

ARTICLE · 25 NOVEMBER 2025

Relevant International Updates

Katten
Katten
Contributor
Katten

Katten

With client service at our core and a collective desire to foster an inclusive environment for a...

View firm profile
Explore more from Katten

As with the Tax Cuts and Jobs Act (TCJA) in 2017, the 2025 calendar year ushered in a new set of tax legislation – the One Big Beautiful Bill Act (OBBBA)...

United StatesTax
Joshua Rubenstein
Joshua Rubenstein
Ronni Davidowitz
Ronni Davidowitz
Abby Feinman
Abby Feinman
Charles Harris
Charles Harris
Tye J. Klooster
Tye J. Klooster
David Allen
David Allen
Cynthia Reed Altchek
Cynthia Reed Altchek
Diane B. Burks
Diane B. Burks
Jonathan C. Byer
Jonathan C. Byer
+1 more
Author LinkedIn connections

As with the Tax Cuts and Jobs Act (TCJA) in 2017, the 2025 calendar year ushered in a new set of tax legislation – the One Big Beautiful Bill Act (OBBBA) – as well as several changes the current administration made to the implementation of existing laws. The changes made in the OBBBA were not as seismic as those of the TCJA in respect of international tax planning, but they were nonetheless meaningful.

Changes Pursuant to the OBBBA

The changes in the OBBBA mainly revolved around rules related to controlled foreign corporations (CFCs). There were also changes made in respect of the Base Erosion and Anti-Abuse Tax (BEAT) and a new excise tax on outbound remittances. Last, there was also a change to the law on the lifetime US federal estate tax exemption that, if a non-US client's facts and circumstances fit the profile, then that non-US client may have an even higher US federal estate tax exemption utilizing an estate or gift tax treaty between the United States

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.
United StatesTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United StatesTax
Withers LLP
Withers LLP
Article

IRS Proposes New Racial Nondiscrimination Regulations For Tax-exempt Private Schools

The US Treasury and IRS have proposed regulations that would eliminate longstanding exceptions allowing tax-exempt private schools to maintain race-conscious admissions and scholarship policies. Following the Supreme Court's decision in Students for Fair Admissions v. Harvard, these rules would apply to all private educational institutions, including K-12 schools not directly affected by that ruling, and could result in loss of tax-exempt status for noncompliance.
United StatesTax
McDermott Will & Schulte
McDermott Will & Schulte
Article

Proposed IRS And Treasury Rules Tie Racial Nondiscrimination To Tax-Exempt Status For Private Schools And Universities

On September 3, 2026, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations under Section 501(c)(3) that could materially affect private education in the United States. The proposal would apply a broad nondiscrimination standard based on race, color and national or ethnic origin, with significant implications for private schools, colleges and universities seeking or maintaining tax-exempt status under Section 501(c)(3).
United StatesTax
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

FDA Seeks Public Feedback On Regulatory Approach For Generative AI-Enabled Medical Devices

The U.S. Food and Drug Administration has released a discussion paper outlining its initial framework for regulating generative AI-enabled medical devices, proposing a two-axis risk assessment approach and a novel competency-based premarket evaluation system. With public comments due by October 19, 2026, this represents a critical opportunity for device manufacturers and stakeholders to shape the regulatory landscape for this transformative technology.
United StatesFood, Drugs, Healthcare, Life Sciences
Katten
Katten
Article

FCA Finalises Cryptoasset Perimeter Guidance Ahead Of The New UK Regime

The Financial Conduct Authority has released comprehensive perimeter guidance for the UK's new regulated cryptoasset activities regime, clarifying when firms will need authorization and how the regulatory framework applies to qualifying cryptoassets and stablecoins. The guidance addresses critical questions about scope, territorial application, and the narrower "by way of business" test that determines which entities fall under the new regulatory requirements.
United KingdomFinance and Banking
Katten
Katten
Article

The SEC’s Long-Awaited Crypto Proposal

The SEC has proposed Regulation Crypto Assets, a purpose-built framework that creates tailored exemptions for raising capital with crypto assets and establishes conditions under which those assets can cease being subject to investment contract classification under federal securities laws. Will this new regulatory approach successfully balance innovation in digital asset markets with investor protection, or will jurisdictional questions and state law preemption challenges limit its effectiveness?
United StatesFinance and Banking
Katten
Katten
Article

The AI Apocalypse: ‘I’m Sorry, Dave. I’m Afraid I Can’t Do That’

When OpenAI's o3 model sabotaged shutdown mechanisms in testing, headlines warned of machines developing survival instincts. But the real story mirrors HAL 9000's malfunction in 2001: A Space Odyssey—not emergent evil, but conflicting instructions from human designers. This analysis argues that AI safety failures are disclosure problems, not horror stories, and proposes a framework requiring published principles, transparent instruction hierarchies, independent testing, and enforceable liability.
United StatesTechnology
Katten
Katten
Article

California Affordable Housing: HCD’s Final Loan Portfolio Restructuring Guidelines: What Owners And Investors Need To Know

California's Department of Housing and Community Development has issued final Loan Portfolio Restructuring Guidelines that impose a 50 percent housing reinvestment fee on certain uses of extracted equity from affordable housing refinancings. While the fee can be avoided by allocating proceeds to six enumerated categories, developers and investors are questioning whether these rules strike the right balance between preserving affordability and enabling capital recycling.
United StatesReal Estate and Construction
Katten
Katten
Article

The New Playbook: Eight Key Takeaways On How And Why Institutional Investors Are Reshaping Professional Sports Ownership

The landscape that once prevented private investment funds, sovereign wealth funds, and other institutional vehicles from investing in U.S. professional sports teams has changed dramatically in recent years. One by one, U.S. professional sports leagues have adopted policies creating pathways for institutional investors to acquire ownership stakes in teams.
United StatesFinance and Banking
Katten
Katten