United States: Tax Treaties

Courts continue to shape the boundaries of state corporate income taxation, particularly in disputes involving P.L. 86-272 – which restricts states’ authority to impose income tax on certain interstate sellers – receipts sourcing, and the classification of business income.

The Pennsylvania Department of Revenue (DOR) recently revised Corporation Tax Bulletin 2019-03, limiting its application to tax years beginning before January 1, 2025. The change creates uncertainty for corporate taxpayers that previously relied on Pennsylvania’s federal consolidated-group approach to avoid a separate state-specific Section 163(j) limitation.

The U.S. tax landscape has undergone dramatic transformation since the Tax Cuts and Jobs Act of 2018, with evolving rules, expiring provisions, and major legislation during President Trump's second term. This analysis examines the six most significant tax developments of the past eight years, from historic estate tax exemption increases to the growing importance of international taxation, and explores what these changes mean for taxpayers, advisors, and business owners navigating today's more stable but sti

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

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.

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

The economic substance doctrine in the U.S. has its roots in case law that aimed to deny tax benefits generated from certain abusive transactions entered into solely or primarily to obtain tax benefits.

The IRS has outlined plans to revise its Criminal Voluntary Disclosure Program (CVDP) in early 2026, with proposed rules aimed at improving consistency and predictability in handling willful tax noncompliance disclosures.

The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework)...