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.

Understanding Sales Tax Versus VAT For Your Global Business

Indirect tax obligations are evolving rapidly as governments modernize their rules for the digital economy. If your organization is working across borders...

United States Tax

MG

MGO CPA LLP

IRS Resumes Significant-Issue Rulings For Corporate Reorganizations And Spin-Offs

The IRS has reversed its 2024 policy and will now issue private letter rulings on significant issues in corporate reorganizations and spin-offs, allowing taxpayers to request guidance on discrete legal matters rather than entire transaction structures.

United States Tax

LL

Liskow & Lewis

The Taxpayer Assistance And Service Act: Title II: American Citizens Abroad

Bipartisan legislation aims to reduce compliance burdens on U.S. citizens living abroad by streamlining overlapping international financial reporting requirements and simplifying tax obligations.

United States Tax

FR

Fox Rothschild LLP

Withholding Taxes And CLO Eligibility Criteria: An Overview Of European Withholding Tax Risks For U.S. CLOs And Potential Solutions

In light of the recent article published by 9fin regarding the adverse implications to U.S. collateralized loan obligations ("CLOs") that resulted from U.K. withholding taxes imposed with respect to a certain dividend financing loan issued by the CFC Group, ...

United States Tax

D

Dechert

Anti-abuse Provisions In Double Tax Treaties: Beneficial Ownership, The EU Danish Cases And U.S. Limitation On Benefits

AO

A&O Shearman

Understanding Tax Obligations For Tribal Citizens

United States Tax

MG

MGO CPA LLP

The Relevance Of Relevance And The Economic Substance Doctrine

United States Tax

RP

Ruchelman PLLC

IRS Criminal Voluntary Disclosure Program (VDP) Changes Take Effect In Early 2026: How Crypto Tax Disclosures And FATCA Reporting Obligations Affect U.S. Tax Compliance

United States Tax

RS

Rotfleisch & Samulovitch P.C.

OECD Pillar Two Side-by-Side Safe Harbor Package: Technical Review And Implications

United States Tax

HK

Holland & Knight

Recent IRS Guidance On Branch Profits Tax Treaty Benefits For Foreign Reverse Hybrid Entities

United States Tax

FL

Foley & Lardner

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

United States Strategy

AG

Akin Gump Strauss Hauer & Feld LLP

Cross-border Trust Strategies: Maximising Jurisdictional Advantages

United States Commercial

GGI Global Alliance

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

United States Employment

RP

Ruchelman PLLC

Relevant International Updates

United States Tax

KM

Katten Muchin Rosenman LLP

The Cannabis Industry’s “Big Tobacco” Moment: What Insurers Need To Know About Murray v. Cresco

United States Cannabis

WE

Wilson Elser Moskowitz Edelman & Dicker LLP

For Whom The Discovery Tolls: Your Privacy Notice May Help Time-Bar Website Wiretapping Claims

United States Privacy

FR

Fox Rothschild LLP

Virtual & Digital Health Digest

United States Healthcare

AP

Arnold & Porter

Ankura CTIX FLASH Update – May 11, 2026

United States Technology

AC

Ankura Consulting Group LLC

Debt's Grip: What Consumer Bankruptcy Reveals About Financial Risk In America (Podcast)

United States Insolvency

BS

Ballard Spahr 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

Before you is the Autumn edition of 2025. This edition features many tax changes resulting from governments, especially in Indonesia, Korea, the Philippines, and Vietnam, raising taxes in order to make ends meet...

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

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

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

United States Tax

D

Dechert

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

US House Passes Bill Targeting 'Unfair Foreign Taxes'

On May 22, 2025, the US House of Representatives passed a bill that includes tax increases on certain foreign persons to target purported unfair taxes imposed by foreign countries.

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

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

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.

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

Trump Administration Disavows The OECD Global Tax Deal

United States Tax

PR

Proskauer Rose LLP

'Interpretive Puzzles': Bruyea v. United States And The Net Investment Income Tax

WL

Withers LLP

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

United States Tax

GT

Greenberg Traurig, LLP

Arizona Residential Rental Tax Changes Effective January 1, 2025

United States Real Estate

WB

Womble Bond Dickinson

2024 Year-End Estate Planning: International Developments

KM

Katten Muchin Rosenman LLP

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

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

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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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