Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
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
United States Tax
AO
A&O Shearman
Article
Florida Judge Determines Property Tax Amendment Ballot Language Defective; Attorney General To Revise
A Florida Circuit Court has ruled that the ballot language for Amendment 3, which proposes changes to homestead property tax exemptions, contains multiple defects that mislead voters about its true effects. The court found that the amendment's title and summary use emotional rhetoric, make improper conclusions, and fail to accurately describe how the measure would impact different classes of property owners and local government taxing authority. The Attorney General now has 10 days to prepare revised ballot
United States Tax
JW
Jones Walker
Article
NYC DOF Finalizes Rules And Sends Notices Implementing The New Pied-à-Terre Tax
New York City's Pied-à-Terre Tax imposes substantial annual surcharges on high-value residential properties that don't serve as primary residences, with rates ranging from 0.8% to 6.5% of assessed value depending on property type and valuation. The Department of Finance has issued implementation guidance and mailed notices to affected property owners, who must now navigate complex exemption requirements and documentation standards by the September 18, 2026 deadline. Critical questions remain unresolved
United States Tax
GT
Greenberg Traurig, LLP
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Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
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
United States Tax
AO
A&O Shearman
Article
Federal Court Vacates IRS Notice 2025-42, Restoring Five Percent Safe Harbor For “Beginning Of Construction” On Wind And Solar Projects
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.
United States Tax
FH
Foley Hoag LLP
Article
Permanent Establishments Series #3: Expanding Into Europe Through A Dutch BV - New York Office Snippet
When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.
United States Tax
LL
Loyens & Loeff
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Corporate Tax

Article
In Chester Chapter 9 Decision, Third Circuit Provides Guidance On Bankruptcy Treatment Of Municipal Revenue Bonds
The Third Circuit Court of Appeals has issued a pivotal ruling in Chester, Pennsylvania's chapter 9 bankruptcy case that examines when municipal revenue bonds maintain their secured status after a city files for bankruptcy protection. The decision analyzes three critical exceptions under Section 552(a) of the Bankruptcy Code that could preserve bondholders' liens on post-bankruptcy revenues, with implications for how municipal financing structures must be crafted to withstand bankruptcy proceedings.
United States Insolvency
HL
Hogan Lovells Cadwalader
Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
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
United States Tax
AO
A&O Shearman
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Transfer Pricing

Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
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
United States Tax
AO
A&O Shearman
Article
Are AI And ESG Redefining Transfer Pricing Roles In Banking
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.
United States Tax
N
NERA
Article
Permanent Establishments Series #3: Expanding Into Europe Through A Dutch BV - New York Office Snippet
When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.
United States Tax
LL
Loyens & Loeff
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