The US Internal Revenue Service  (IRS) issued an Office of Chief Counsel memorandum clarifying that a controlled foreign corporation (CFC) is not eligible for a dividends received deduction under section 245A. This memorandum provides

The US Department of the Treasury announced on 29 October 2024 that the US and Taiwan, under the auspices of the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office in the United States (TECRO), will begin

The US Internal Revenue Service (IRS) issued an updated practice unit titled, ‘IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII) on 24 October 2024. This revision eliminates references to unavailable resources and replaces the

As stated in a release from the Andorran government officials from Andorra and Germany are set to begin the first round of negotiations for an income tax treaty in November 2024. The Head of Government, Xavier Espot, the Minister of Foreign

Liechtenstein and the US delegation met on 22 October 2024 to discuss bilateral cooperation. Liechtenstein expressed interest in signing an income tax treaty with the US in the meeting. If an agreement is reached, it will be the first tax

Germany’s Lower House of Parliament of Germany (Bundestag) passed the Annual Tax Act 2024 on 18 October 2024. The Bundestag has implemented 59 changes to the draft law based on the Finance Committee's recommendation. The Annual Tax Act 2024