United States: Tax Treaties

U.S. multinationals expanding their European server infrastructure face critical questions about permanent establishment risks. When do data centers and servers create a taxable presence in Europe...

This comprehensive bulletin examines critical tax developments across 12 Asian jurisdictions, including China's intensified scrutiny of Hong Kong holding company structures for dividend withholding tax benefits, Singapore's implementation of Pillar Two global minimum tax registration requirements, and India's new Income Tax Act taking effect.

Tax executives face material transactions that cannot wait for litigation to resolve interpretive uncertainty. This practical guide explores four critical IRS mechanisms—prefiling agreements, closing agreements, private letter rulings, and tax opinions—that provide varying levels of certainty for managing tax exposure before issues reach examination. Through conversations between controversy and transactional practitioners, discover when and how to deploy these tools along the continuum from inf

In this article, we explore how income, sales, and employment are taxed in Indian Country — helping Tribal leaders, advisors, and members make informed decisions that support sovereignty and long-term goals.

The economic substance doctrine in the U.S. has its roots in case law that aimed to deny tax benefits generated from certain abusive transactions entered into solely or primarily to obtain tax benefits.

The IRS has outlined plans to revise its Criminal Voluntary Disclosure Program (CVDP) in early 2026, with proposed rules aimed at improving consistency and predictability in handling willful tax noncompliance disclosures.

Earlier this month, we published a briefing summarising the 'retaliatory' tax measures in the 'One Big Beautiful Bill Act' Bill (the "Bill"), which target certain overseas taxpayers...

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017...

The US Senate Finance Committee has released a substitute (the "Senate version") for the tax provisions of the "One Big Beautiful Bill," the budget reconciliation bill currently under consideration by Congress.