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US International Tax Alerts

Updates on tax developments affecting cross-border business.

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Tax developments affecting cross-border business

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Treasury, IRS release final and proposed regulations under section 987 and related rules
January 23, 2025

Trump administration’s America First Trade Policy, potential tariffs on horizon for Mexico/Canada/China goods, CBP proposed action to limit de minimis rule
January 23, 2025

New OECD guidance addresses Pillar Two incentives and administration
January 19, 2025

Final regulations address disregarded payment loss and dual consolidated loss rules
January 16, 2025

Treasury, IRS release proposed cloud transaction sourcing regulations
January 15, 2025

Final digital content and cloud transaction regulations issued
January 15, 2025

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

Proposed regulations addressing certain issues under the dual consolidated loss rules and new rules for “disregarded payment losses” and the check-the-box entity classification regulations
August 14, 2024

New OECD document provides additional detail on implementing Pillar Two, outlines process to determine if local implementation is “qualified”
June 25, 2024

New OECD guidance identifies qualifying and covered jurisdictions under Amount B
June 21, 2024

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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