Worldwide: Tax Treaties

Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.

The US Court of Federal Claims recently addressed a critical question for Canadian exempt organizations earning US-source income: can they rely on fiscal transparency rules to claim treaty benefits through investment vehicles? The court's ruling in The South Saskatchewan Community Foundation Inc. v. United States examines when charitable organizations may look through intermediary entities to access tax exemptions under the US-Canada tax treaty, with significant implications for cross-border investment

The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.

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

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

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

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.