United States: Tax Treaties

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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.

New Section 892 Regulations: Action Points For Private Fund Sponsors And Non-U.S. Pension Plan & Sovereign Investors

The Treasury also proposed new regulations that introduce a limited safe harbor for loan origination activities (the 2025 Proposed Regulations).

United States Strategy

AG

Akin Gump Strauss Hauer & Feld LLP

Cross-border Trust Strategies: Maximising Jurisdictional Advantages

Entrepreneurs and professionals with global interests face a unique challenge: the US tax system reaches far beyond its borders. US citizens...

United States Commercial

GGI Global Alliance

An Increasingly Less Remote Situation: New O.E.C.D. Model Treaty Commentary On Remote Workers

Remote work is one of COVID-19's enduring legacies. What began as something necessary for health and safety has become a fairly conventional practice.

United States Employment

RP

Ruchelman PLLC

Relevant International Updates

As with the Tax Cuts and Jobs Act (TCJA) in 2017, the 2025 calendar year ushered in a new set of tax legislation – the One Big Beautiful Bill Act (OBBBA)...

United States Tax

KM

Katten Muchin Rosenman LLP

IRS Guidance Clarifies Tax Treaty Benefits On Branch Profits Tax For Funds And Multinationals Using Reverse Hybrids

United States Tax

GT

Greenberg Traurig, LLP

The Methanex Case: Implications Of 'Treaty Shopping' And Consequences On U.S. Tax Planning For Americans

United States Tax

RS

Rotfleisch & Samulovitch P.C.

How To Form A Foreign-Owned U.S. Limited Liability Company That Avoids Bank Rejections, 5472 Penalties, And State Registration Traps

United States Commercial

HS

Harris Sliwoski

Asia Tax Bulletin - Autumn 2025

MB

Mayer Brown

New IRS Guidance Provides Clarity On Treaty Relief For Common Cross-Border Investment Structures

United States Tax

C

Caldwell

New IRS Guidance On Tax Treaties Provides Reassurance For Common US Cross-Border Investment Structures

MB

Mayer Brown

Business Profits Under The Double Taxation Avoidance Treaty Between Mexico And The Netherlands

AM

Alvarez & Marsal

Asia Tax Bulletin - Summer 2025

MB

Mayer Brown

The Senate Finance Committee's Proposed Section 899 Would Increase Taxes On Certain Foreign Individuals And Entities Majority-Owned By Such Individuals

United States Tax

ST

Simpson Thacher & Bartlett

Is Revenge A Dish Best Served Under The Tax Code?

United States Tax

CW

Cadwalader, Wickersham & Taft LLP

USPTO Proposes Dramatic Restrictions For Inter Partes Review Institution

United States IP

OB

Osha Bergman Watanabe & Burton LLP

Visa Turbulence: Navigating Your H-1B Future In A Shifting U.S. Landscape (Video)

United States Immigration

Gs

Green and Spiegel

Federal Circuit: Priority Document That 'Broadly Outlines' Possible Structures Fails To Provide Adequate Written Description Support For Subgenus Of Linkers In Antibody-Drug Conjugate

United States IP

AG

Akin Gump Strauss Hauer & Feld LLP

How The JAMS AI Rules Can Streamline Discovery For AI-Related Disputes

United States Litigation

J

JAMS

Food Venture Financing News – Weekly Issue No. 264

United States Commercial

DW

Davis Wright Tremaine

US Advances Retaliatory Tax Measures: What Private Capital Professionals Need To Know

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...

United States Tax

KL

Herbert Smith Freehills Kramer LLP

PER-10/PJ/2025, New Procedures For Tax Information Exchange

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...

AM

Alvarez & Marsal

US Senate Finance Committee Makes Changes To Proposed Section 899

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.

United States Tax

MB

Mayer Brown

Impact Of Section 899 On Private Equity And Non-U.S. Investors

The One Big Beautiful Bill Act, a budget reconciliation bill, passed the United States House of Representatives vote on May 22, 2025, and is currently under Senate consideration.

United States Tax

D

Dechert

Proposed Section 899 - The Retaliatory Tax Regime

United States Tax

KD

Kelley Drye & Warren LLP

House Passes Tax Bill: Proposed Legislation Would Increase US Taxes On Many Foreign Individuals, Entities And Governments

United States Tax

HB

Haynes and Boone

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

United States Tax

KG

K&L Gates LLP

Section 899: Potential Tax Increases For Canadians Investing In The U.S.

United States Tax

GW

Gowling WLG

Senator Tillis Introduced A Bill Taxing Proceeds Of Litigation Financing Agreements

United States Tax

PR

Proskauer Rose LLP

US House Passes Bill Targeting 'Unfair Foreign Taxes'

United States Tax

MB

Mayer Brown

Summary Of Proposed Section 899 Of The US Internal Revenue Code And Its Impact On Section 892 Benefits And Tax Treaties

United States Tax

M

Mintz

Section 899: Proposed Legislation Would Increase US Tax Rates On Many Foreign Individuals, Companies, And Governments

United States Tax

GT

Greenberg Traurig, LLP

Congress Proposes A 'Big Stick' To Target Discriminatory Tax Measures

United States Tax

MB

Mayer Brown

International Philanthropy: Considerations For The Globally Minded Donor

United States Tax

KM

Katten Muchin Rosenman LLP

Summary Of Proposed Section 899 Of The US Internal Revenue Code And Its Impact On Section 892 Benefits And Tax Treaties

Proposed Section 899, introduced as part of the "Defending American Jobs and Investment Act" (H.R. 591) and incorporated into the House Ways...

United States Tax

M

Mintz

Section 899: Proposed Legislation Would Increase US Tax Rates On Many Foreign Individuals, Companies, And Governments

Under the proposed Defending American Jobs and Investment Act, introduced in the House of Representatives and approved by the House Ways and Means Committee on May 14, 2025, as part of the Trump administration's tax package known as "The One, Big, Beautiful Bill."

United States Tax

GT

Greenberg Traurig, LLP

Congress Proposes A 'Big Stick' To Target Discriminatory Tax Measures

At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules...

United States Tax

MB

Mayer Brown

International Philanthropy: Considerations For The Globally Minded Donor

Many of our clients are interested in engaging in global philanthropy. These individuals often want to benefit charitable causes outside of the United States while still being able to maintain an income tax deduction ...

United States Tax

KM

Katten Muchin Rosenman LLP

Taxing Covered Gifts And Bequests: Key Takeaways From The Final § 2801 Regulations

United States Tax

FF

Farrell Fritz, P.C.

Big Law Redefined: Immigration Insights Episode 2 | Navigating US Immigration Law And Tax Complexities For High-Net-Worth Individuals (Podcast)

In this episode of Greenberg Traurig's Immigration Insights series, host Kate Kalmykov is joined by GT colleague and Tax Practice Shareholder, Erez Tucner, to explore the intersection of U.S. immigration and tax considerations for high-net-worth individuals.

United States Tax

GT

Greenberg Traurig, LLP

Arizona Residential Rental Tax Changes Effective January 1, 2025

Effective January 1, 2025, Arizona property owners will no longer be required to collect and remit city Transaction Privilege Tax (TPT) on residential rental income for long-term stays of 30 consecutive days or more.

United States Real Estate

WB

Womble Bond Dickinson

2024 Year-End Estate Planning: International Developments

It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024.

KM

Katten Muchin Rosenman LLP

Master State And Local Taxes For Your U.S. Expansion

The U.S. continues to captivate global businesses, attracting significant foreign direct investment (FDI). It's easy to understand why: Entering the U.S. market is a strategic move that gives your business access.

United States Tax

MG

MGO CPA LLP

5 Tips For Setting Up Your Business In The U.S.

United States Tax

MG

MGO CPA LLP

Using IRS Form 8833 For Tax Treaty Benefits: Beginner's Guide (2024)

GL

Gordon Law

Understanding U.S. Taxes For Your Foreign Business

United States Tax

MG

MGO CPA LLP

Forms 8804, 8805, And Section 1446 Withholding: Tax Guide For Foreign Partnerships

United States Tax

GL

Gordon Law

Clarifying Cross-Border Transactions: IRS Targets International Partnership Tax Rules

United States Tax

ML

Marcum

GE Financial Investments: What Determines Residency?

CW

Cadwalader, Wickersham & Taft LLP

RPJ's Nafsika Karavida Featured In HR.com Article: Remote Work: Navigating U.S. Employment Laws While Living Abroad

United States Employment

RP

Reavis Page Jump LLP

US Multinationals Must Be Strategic On Pillar Two Compliance

United States Tax

AM

Alvarez & Marsal

Section 1446(f) Withholding And Private Fund Admissions And Withdrawals

United States Tax

FL

Foley & Lardner

Treasury Department Confirms Suspension Of U.S.-Russia Income Tax Treaty

United States Tax

HK

Holland & Knight

Earning My Credits: Life At Ruchelman P.L.L.C.

United States Tax

RP

Ruchelman PLLC

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations For Some US Taxpayers

United States Tax

KM

Katten Muchin Rosenman LLP

Proskauer's Hedge Start: Key Structuring Issues

United States Finance

PR

Proskauer Rose LLP

Foreign Pensions And The US – What Globally Mobile Individuals Need To Know To Protect Your Retirement (Video)

Worldwide Employment

WL

Withers LLP

U.S. Estate Tax: Heading Toward The Cliff On January 1, 2026

United States Tax

OE

O'Sullivan Estate Lawyers LLP

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Latest Videos

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You Can Run But You Can't Hide From The IRS (Video)

HK

Holland & Knight

Trending Video: New Anti-Abuse Tax Provisions (Video)

RG

Ropes & Gray LLP

New Anti-Abuse Tax Provisions (Video)

RG

Ropes & Gray LLP

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