United States: Tax Treaties

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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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