Worldwide: 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.

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

In Chief Counsel Advice AM 2025-002 (dated Sept. 8, 2025; released Sept. 19, 2025) (Memorandum), the IRS analyzed how U.S. income tax treaties apply to the branch profits tax...

United States Tax

GT

Greenberg Traurig, LLP

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

On April 22, 2025, the Judicial Committee of the U.K. Privy Council released a pivotal decision in Methanex Trinidad v. Board of Inland Revenue ([2025] UKPC 20).

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

Despite all the geopolitical issues swirling around the United States (or perhaps because of them), our law firm has never been busier helping foreign companies establish a business here.

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

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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

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

United States Tax

KL

Herbert Smith Freehills Kramer LLP

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

AM

Alvarez & Marsal

US Senate Finance Committee Makes Changes To Proposed Section 899

United States Tax

MB

Mayer Brown

[PODCAST] Utilizing Co-Mediation - Bringing Together Multiple Perspectives To Reach Effective Settlements

United States Litigation

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JAMS

Early Mediation: Is Your Case A Likely Candidate?

United States Litigation

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JAMS

AI Innovation Is Accelerating, But Oversight Is Fragmented: Why ADR Must Fill The Governance Gap

United States Litigation

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JAMS

Hot Topics In International Trade A Tariff Christmas Message For US Kids (Video)

United States International

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Braumiller Law Group, PLLC

What Foundations And Other Nonprofits Need To Know About The Foreign Agents Registration Act

United States Government

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WilmerHale

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

The One Big Beautiful Bill Act (the "Bill"), which was passed by the House of Representatives...

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

"The One, Big, Beautiful Bill" (H.R. 1, 119th Congress) (the OBBB) is a tax package advanced as a part of the proposed Defending American Jobs and Investment Act.

United States Tax

HB

Haynes and Boone

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

Retaliatory tax provisions contained in H.R. 1, the "One Big Beautiful Bill Act" that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions, including US operations of foreign multinational groups and inbound investments.

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

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

United States Tax

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Farrell Fritz, P.C.

Another Taxpayer Allowed Treaty-Based Foreign Tax Credit Against N.I.I.T.

RP

Ruchelman PLLC

Trump And House Republicans Take Aim At The Global Minimum Tax And Domestic Tax Measures

AO

A&O Shearman

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

§ 2801 of the Internal Revenue Code of 1986, as amended (the "Code") imposes a tax a U.S. citizen or resident who receives a "covered gift" or "covered bequest" from certain individuals...

United States Tax

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Farrell Fritz, P.C.

Another Taxpayer Allowed Treaty-Based Foreign Tax Credit Against N.I.I.T.

The application of the foreign tax credit to the net investment income tax ("N.I.I.T.") has been a recurring battle in courtrooms in recent years. In the most recent installment...

RP

Ruchelman PLLC

Trump And House Republicans Take Aim At The Global Minimum Tax And Domestic Tax Measures

Day one of the Trump administration and the impact of the new U.S. President and Republican-controlled House and Senate is being felt in many areas, including in the international tax sphere.

AO

A&O Shearman

Trump Administration Disavows The OECD Global Tax Deal

United States Tax

PR

Proskauer Rose 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.

This article is part of an ongoing series, "Navigating the Complexities of Setting Up a Business in the USA".

United States Tax

MG

MGO CPA LLP

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

As an American, it doesn't matter where you live or work. All your income is taxable by the IRS.

GL

Gordon Law

Understanding U.S. Taxes For Your Foreign Business

Navigating the U.S. tax system is a critical aspect of doing business in the United States. Unlike other countries with a single national tax system, the U.S. has a multi-layered structure that includes federal...

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

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O'Sullivan Estate Lawyers LLP

Tax Treaty With Chile Enters Into Force

United States Tax

CM

Crowell & Moring LLP

US-Chile Bilateral Income Tax Treaty Enters Into Force

KL

Herbert Smith Freehills Kramer LLP

Tax-related Measures In Investor-State Arbitration

United States Tax

W

WilmerHale

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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)

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Ropes & Gray LLP

New Anti-Abuse Tax Provisions (Video)

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Ropes & Gray LLP

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