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.

Key US Tax Considerations When Investing In Or Forming A Fund

Navigating the complex landscape of US federal income tax rules is crucial for investors and sponsors in private equity, venture capital, and hedge funds. Understanding how different investor categories—from US taxable entities to foreign pension funds—face distinct tax sensitivities can significantly impact investment returns and structural decisions when forming or investing in funds.

United States Tax

TL

Torys LLP

IRS Issues Transfer Tax Safe Harbor For Contributions To Trump Accounts

The IRS recently released Revenue Procedure 2026-25, which establishes a transfer tax safe harbor for certain contributions to Trump Accounts.

United States Tax

KM

Katten Muchin Rosenman LLP

Preventing Unexpected Tax Liability In Cross-Border Dispute Payments

U.S. companies making cross-border dispute payments face unexpected tax liability when withholding requirements are overlooked. Understanding how the origin of the claim doctrine characterizes settlements and damages as FDAP income can prevent costly surprises and ensure proper tax compliance in international dispute resolution.

United States Tax

DW

Dickinson Wright PLLC

Permanent Establishments Series #2: Data Centers And Servers – New York Office Snippet

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...

United States Tax

LL

Loyens & Loeff

Asia Tax Bulletin - Summer 2026

MB

Mayer Brown

Certainty By Design: A Practical Guide To Prefiling Agreements, Closing Agreements, Private Letter Rulings, And Tax Opinions

United States Tax

DS

Dinsmore & Shohl

Letter From The Editors: The Next Chapter Of BrassTax

United States Tax

HL

Hogan Lovells Cadwalader

Transfer Pricing, MAP, And Fast Track: The Forces Reshaping Tax Controversy

United States Tax

SR

McDermott Will & Schulte

Podcast - U.S. Real Estate Tax Planning For Global Families

United States Real Estate

HK

Holland & Knight

US Treasury Issues Additional Proposed Regulations Under Section 892 Providing Transitional Relief For Foreign Government Investors

United States Tax

MB

Mayer Brown

IRS Releases Proposed Regulations That Provide Clarification And Transitional Relief For Proposed Section 892 Regulations

United States Tax

TL

Torys LLP

2026 International Tax Reform Guide For CFOs And Tax Directors

United States Tax

MG

MGO CPA LLP

Understanding Sales Tax Versus VAT For Your Global Business

United States Tax

MG

MGO CPA LLP

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

United States Tax

LL

Liskow & Lewis

Department Of Justice Announces Record Healthcare Fraud Takedown Led By New Fraud Enforcement Division

United States Criminal

GP

Goodwin Procter LLP

Sanctions Update: July 13, 2026

Worldwide International

SJ

Steptoe LLP

Space Business Review June 2026

United States Finance

ML

Milbank LLP

What The Trump v. Slaughter Decision Means For Independent Agency-Regulated Companies

United States Government

HK

Holland & Knight

Supreme Court Immigration Update: Border Asylum Access, TPS For Haiti And Syria, And Employer Next Steps

United States Immigration

FL

Fennemore

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

In recent years, we have seen tax authorities increasingly relying on anti-abuse arguments to deny relief under double tax treaties.

AO

A&O Shearman

Understanding Tax Obligations For Tribal Citizens

In this article, we explore how income, sales, and employment are taxed in Indian Country — helping Tribal leaders, advisors, and members make informed decisions that support sovereignty and long-term goals.

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

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.

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

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

United States Commercial

HS

Harris Sliwoski

Asia Tax Bulletin - Summer 2025

We present to you the Summer 2025 edition of the Asia Tax Bulletin. It contains tax developments in Asia on a host of topics, such as Hong Kong's and Japan's tax legislation...

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

On June 16, 2025, the Senate Finance Committee released its version of a tax bill, containing new proposed Section 899 of the Internal Revenue Code (which is similar to a provision approved in the earlier House tax bill).

United States Tax

ST

Simpson Thacher & Bartlett

Is Revenge A Dish Best Served Under The Tax Code?

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as the "revenge tax."

United States Tax

HL

Hogan Lovells Cadwalader

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

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

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

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

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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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