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US International Tax Alerts
Updates on tax developments affecting cross-border business.
Recent alerts
Final regulations terminate section 367(d) application to certain repatriated IP
October 11, 2024
New LB&I audit guidelines for foreign tax redeterminations
October 8, 2024
New OECD guidance identifies qualifying and covered jurisdictions under Amount B
June 21, 2024
Archive
Final FIRPTA regulations on domestically controlled QIEs
April 26, 2024
New Pillar One Amount B methodology optional for countries under newly released guidance
February 24, 2024
Notice 2024-16 addresses treatment of section 961(c) basis adjustments
January 12, 2024
Notice 2023-80 lays out interaction of Pillar Two and foreign tax credits
December 22, 2023
New OECD administrative guidance provides additional detail regarding Pillar Two compliance
December 21, 2023
UPDATED: IRS, Treasury release proposed regulations, correction under section 987 and related rules
December 20, 2023
IRS, Treasury release proposed regulations under section 987 and related rules
November 17, 2023
OECD Pillar One – Amount A Multilateral Convention
October 30, 2023
Notice 2023-55 offers temporary relief from certain provisions in final FTC regs
July 26, 2023
OECD Pillar One – Amount B report and public consultation
July 24, 2023
US International Tax Alert: New OECD guidance provides needed detail regarding Pillar Two implementation
July 21, 2023
Proposed regulations terminate section 367(d) application to certain repatriated IP
May 30, 2023
Key tax considerations related to the Turkish economy being classified as highly inflationary
February 8, 2023
OECD releases Pillar Two Administrative Guidance
February 7, 2023
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