Worldwide: Tax Treaties

The IRS has finalized new Section 987 regulations that fundamentally change how businesses with foreign operations report currency gains and losses, with compliance beginning for the 2025 tax year. These regulations require taxpayers to calculate cumulative foreign currency positions dating back to 2006 or entity inception, while IRS Notice 2026-17 offers a simplified election that may reduce administrative burden for qualifying businesses. Understanding these changes now is critical to avoid penalties, ens

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex

The US Treasury and IRS have issued new proposed regulations modifying the applicability dates for Section 892 rules affecting foreign government investors, providing crucial transitional relief and grandfathering protection...

The US Internal Revenue Service has revised the applicability dates for proposed regulations under Section 892 affecting foreign government investments in the United States, providing crucial clarity on when new...

International tax reform in 2026 introduced structural changes that affect how global income is classified, included, deducted, and limited.

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.

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...

The United States Internal Revenue Service (IRS) has issued new guidance that provides reassurance regarding the application of U.S. income tax treaties to widely used cross-border investment structures...