Tax Law and International Tax Law

As the global tax controversy landscape evolves and becomes more polarized, marked by cross-border audits and mounting pressure on revenue authorities to collect tax, Jones Day partners examine how geopolitical pressure and rising revenue demands are reshaping tax disputes worldwide. The discussion highlights the complexity of navigating uncertain tax environments where authorities are increasingly sharing information across borders and deploying sophisticated anti-abuse provisions.

Battery storage developers and equipment manufacturers face complex new Prohibited Foreign Entity rules that restrict federal tax credit eligibility based on ties to certain foreign entities, primarily China. These rules create three categories of restrictions affecting the ITC, PTC, and 45X credits, with compliance requirements that remain unclear despite limited Treasury guidance.

When Congress enacted the One Big Beautiful Bill Act in July of last year, many technology companies breathed a collective sigh of relief. The legislation largely reversed one of the most unpopular business tax...