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.

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

CW

Cadwalader, Wickersham & Taft LLP

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

Trump Administration Passes The One Big Beautiful Bill Act

United States Tax

FL

Foley & Lardner

From Copyright Case To AI Data Crisis: How The New York Times v. OpenAI Reshapes Companies' Data Governance And EDiscovery Strategy

United States Technology

NM

Nelson Mullins Riley & Scarborough LLP

Blockchain 2025 - Trends And Developments

United States Technology

WS

Winston & Strawn LLP

Artificial Intelligence 2025 - Trends And Developments

United States Technology

SJ

Steptoe LLP

Tariffs And The Future Of U.S. Beef

United States International

BG

Braumiller Law Group, PLLC

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

Many of our clients are interested in engaging in global philanthropy. These individuals often want to benefit charitable causes outside of the United States while still being able to maintain an income tax deduction ...

United States Tax

KM

Katten Muchin Rosenman LLP

Taxing Covered Gifts And Bequests: Key Takeaways From The Final § 2801 Regulations

§ 2801 of the Internal Revenue Code of 1986, as amended (the "Code") imposes a tax a U.S. citizen or resident who receives a "covered gift" or "covered bequest" from certain individuals...

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)

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Gordon Law

2024 Year-End Estate Planning: International Developments

It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024.

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Katten Muchin Rosenman LLP

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

The U.S. continues to captivate global businesses, attracting significant foreign direct investment (FDI). It's easy to understand why: Entering the U.S. market is a strategic move that gives your business access.

United States Tax

MG

MGO CPA LLP

5 Tips For Setting Up Your Business In The U.S.

This article is part of an ongoing series, "Navigating the Complexities of Setting Up a Business in the USA".

United States Tax

MG

MGO CPA LLP

Using IRS Form 8833 For Tax Treaty Benefits: Beginner's Guide (2024)

As an American, it doesn't matter where you live or work. All your income is taxable by the IRS.

GL

Gordon Law

Understanding U.S. Taxes For Your Foreign Business

United States Tax

MG

MGO CPA LLP

US Multinationals Must Be Strategic On Pillar Two Compliance

The divergence between US and European approaches to Pillar Two raises a question for US multinationals that have traditionally located holding companies...

United States Tax

AM

Alvarez & Marsal

Section 1446(f) Withholding And Private Fund Admissions And Withdrawals

A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or business within the United States ("ECI")...

United States Tax

FL

Foley & Lardner

Treasury Department Confirms Suspension Of U.S.-Russia Income Tax Treaty

The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation...

United States Tax

HK

Holland & Knight

Earning My Credits: Life At Ruchelman P.L.L.C.

Credits and externship credits co-mingled during my time at Ruchelman P.L.L.C. While I sought to gain externship credits and learn about the tax world, I spent a lot of time learning about tax credits...

United States Tax

RP

Ruchelman PLLC

Proposed Regulations May Mitigate Certain US Tax Reporting Obligations For Some US Taxpayers

United States Tax

KM

Katten Muchin Rosenman LLP

Proskauer's Hedge Start: Key Structuring Issues

United States Finance

PR

Proskauer Rose LLP

Foreign Pensions And The US – What Globally Mobile Individuals Need To Know To Protect Your Retirement (Video)

Worldwide Employment

WL

Withers LLP

U.S. Estate Tax: Heading Toward The Cliff On January 1, 2026

United States Tax

OE

O'Sullivan Estate Lawyers LLP

Tax Treaty With Chile Enters Into Force

United States Tax

CM

Crowell & Moring LLP

US-Chile Bilateral Income Tax Treaty Enters Into Force

KL

Herbert Smith Freehills Kramer LLP

Tax-related Measures In Investor-State Arbitration

United States Tax

W

WilmerHale

U.S.-Chile Income Tax Treaty Enters Into Force

AO

A&O Shearman

IRS Targets Malta Pension Plans: Compliance Options

GR

Gray Reed & McGraw LLP

Peter Barnes Comments On Pillar 2 Signing Deadline Delayed

United States Tax

CD

Caplin & Drysdale

U.S. Income Tax Treaty Update

RP

Ruchelman PLLC

Christensen V. U.S. – Reducing The N.I.I.T. By Claiming An F.T.C.

United States Tax

RP

Ruchelman PLLC

Too Bad To Be True – Code §§267a And 894(C) Signal The End For Cross Border Hybrids

RP

Ruchelman PLLC

US-Chile Income Tax Treaty Approval Process Continues

KL

Herbert Smith Freehills Kramer LLP

Home Is Where The Heart Is (And Where The IRS Will Try To Find You): Thinking Of Living Abroad? Even ExPats May Have To Pay U.S. Taxes (Podcast)

United States Tax

LS

Lowenstein Sandler

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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)

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Ropes & Gray LLP

New Anti-Abuse Tax Provisions (Video)

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Ropes & Gray LLP

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