Tax Law and International Tax Law

Colorado's H.B. 26-1223 represents a major shift in the state's tax landscape, bringing downloaded software, remotely accessed applications, and SaaS offerings under the sales and use tax umbrella. What does this mean for businesses operating in Colorado, and how should they prepare for the changes taking effect in 2027?

Texas legislators are taking aim at the state's data center sales and use tax exemption, with bipartisan support emerging for potential repeal or modification. The exemption, which has cost the state an estimated $3.3 billion in foregone revenue—far exceeding original projections—faces scrutiny as lawmakers prepare for a constrained budget environment while responding to growing local opposition over electricity demand, water usage, and community impacts.

California's Department of Tax and Fee Administration held its first implementation workshop on Senate Bill 122, which extends sales and use tax to digital software and SaaS starting January 1, 2027. The workshop revealed significant unresolved questions about sourcing rules, the $5 million threshold mechanism, custom versus prewritten software distinctions, and the human-effort exemption that will require emergency regulations and potentially litigation to clarify.

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

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

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 US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

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

Banking groups are under pressure to transform their operating models due to digitalization, changing customer expectations, and heightened ESG requirements. As AI platforms, data governance, and ESG frameworks reshape value creation and risk allocation, the traditional transfer pricing roles and cost-based remuneration models in banking may need fundamental reassessment to reflect evolving business realities.

Cyber‑enabled cargo theft is a modern form of freight theft in which criminals use digital impersonation, stolen credentials and system manipulation to fraudulently obtain cargo...

The Autumn Budget contained a range of pensions-related announcements with implications for employers and trustees of all occupational pension schemes.

The Chancellor has today announced her highly anticipated autumn Budget.