Daily Tax Report ®
Levi’s Heir in Congress Pushes End to Tax Loophole for Ultrarich
One of the wealthiest House Democrats will propose a bill Thursday that would edit the tax code to make it harder for ultrarich Americans to avoid paying taxes.
Practitioner Insights
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Ralph Carnicer
Filed
S. Vasudevan
Lakshmikumaran & Sridharan
Patricia Clements
VF Law
Bloomberg Tax Journals
View MoreOECD Clarifies Home Office Permanent Establishment Rules: Part 2
The OECD introduces new metrics for assessing permanent establishment risk in cross-border remote work.
California Supreme Court Clarifies Trust Amendment Standards
A California litigator’s framework for navigating exclusivity, delivery, and intent after Haggerty is presented.
How Countries Stack Up in OECD’s 2024 APA Statistics Report
The OECD’s recently released 2024 Advance Pricing Agreement and Mutual Agreement Procedure statistics shine a light on the effectiveness of countries APA and MAP programs.
Tax Developments
View MoreIRS Notice: Foreign Tax Credit Limitation on Section 951A PTEP Distributions (IRC §960(d)(4))
The IRS has published a notice announcing its intent to issue proposed regulations regarding I.R.C. §960(d)(4), which disallows a foreign tax credit for 10 percent of foreign income taxes paid ...
IRS Notice: Transition Rule for Dividends Under CFC Anti-Avoidance Provisions (IRC §951(a)(2)(B))
The IRS has published a notice announcing forthcoming proposed regulations implementing a transition rule under the One Big Beautiful Bill Act that modifies how I.R.C. §951(a)(2)(B) applies to certain dividends ...
IRS PLR: Proposed Transaction Not Subject to Capital Gain, Loss Recognition; Related Rulings (IRC §355)
The IRS has published a private letter ruling on I.R.C. §§355 and 368 regarding the recognition of capital gain or loss, if any, pursuant to a series of proposed transactions ...
PODCASTS
Companies Face Tariff-Induced Transfer Pricing Audit Risks
Enrolled Agents Anticipate IRS Chaos for Next Tax Filing Season
Congressional Deadline on Shutdown Deal Adds to IRS Challenges
IP Poses Risks, Opportunities for Companies' Tariff Planning
IRS Shakeup: How Is the US Tax Agency Adapting to Trump's Vision?
Since President Donald Trump took office, the IRS has faced transformative changes, including a substantial reduction in its workforce and the appointment of seven different commissioners or acting commissioners.
Latest Stories
China Politburo Prioritizes Boosting Domestic Demand in 2026
China’s top leaders made strengthening domestic demand their top economic priority for 2026, as Beijing seeks a buffer against risks from global trade.
US Trade Chief Says China Has Complied With Terms of Trade Deals
Trade Representative
Week in Insights: Swiss Wealth Tax Rebuff Is a Lesson, Not an End
This week, experts analyzed KPMG AI usage in performance reviews, Netflix’s transfer pricing court victory in India, and more.
India Urged to Provide Clarity on Permanent Establishment Rules
India’s tax department must provide greater clarity on when a global company operating in the country can be called a permanent establishment and how its profits would be calculated, a former senior India tax department official said Saturday.
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- Transfer Pricing Report
- The Exchange: Tax Insights & Commentary
China Politburo Prioritizes Boosting Domestic Demand in 2026
China’s top leaders made strengthening domestic demand their top economic priority for 2026, as Beijing seeks a buffer against risks from global trade.
Sweden Tax Court Issues Advance Notice Clarifying Dividend Taxation Regarding Corporate Restructuring for Transferring Profits
The Swedish Tax Court Nov. 21 issued Advance Notice No. 19-25/D, clarifying the taxation of dividends regarding two corporate restructuring alternatives for transferring profits between companies. The taxpayer, an individual, ...
Philippines News Agency Announces Reduction in Real Property Taxes for Specified Independent Power Producers
The Philippine News Agency Dec. 3 announced the President’s Nov. 28 signing of Executive Order No. 106, reducing real property taxes (RPT) for specified independent power producers (IPPs) for calendar ...
Norway Gazettes Regulation Setting Asset Valuations, Work-Related Deductions for 2025
The Norwegian Official Gazette Dec. 3 published Regulation No. FOR-2025-12-01-2404, setting asset valuations and work-related deductions for the 2025 tax assessment. The regulation includes measures setting: 1) the asset value ...
Taiwan Gazettes Order Amending Individual Income Tax Rules for Investments in High-Risk Startup Companies
The Taiwanese Executive Yuan Gazette Nov. 27 published Ministry of Economic Affairs Order No. 11451033750 and Ministry of Finance Order No. 11404669500, amending individual income tax rules for investments in ...
South Africa Gazettes Notice on Regulations for AEOI Under CARF, CRS
The South African Official Gazette Nov. 28 published Notice No. 6886, on regulations implementing the OECD Crypto-Asset Reporting Framework (CARF), and updating the common reporting standard (CRS) regarding automatic exchanges ...
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