Foreign-owned companies operating in the US want assurance that a new anti-abuse measure in Republicans’ 2025 tax law won’t result in bigger tax bills because of the way it interacts with other parts ...

On October 20, 2025, the Treasury and the IRS released proposed regulations (REG‑109742‑25 (the “Proposed Regulations”)) that would remove the “foreign‑controlled domestic corporation” look‑through ...

Under Section 897, foreign corporations and nonresident aliens are generally subject to US federal income tax on any gain arising from the disposition of a US real property interest (USRPI), which may ...

The Supreme Court on Thursday upheld a provision of the 2017 tax law that instituted a one-time tax on earnings held in foreign corporations, but the justices avoided broader questions about ...

Globalization has created extraordinary opportunities for U.S. taxpayers and multinational businesses. Yet, it has also placed U.S. accountants at the center of a fast-moving regulatory environment.

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