In the IRS and Treasury Priority Guidance Plan for 2024/25, issued on 3 October 2024, there is a plan for a new section 482 guidance project to provide guidance for taxpayers consistent with Amount B of Pillar One. The OECD Amount B Guidance

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

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

The Swiss State Secretariat for International Finance has announced that the protocol amending the 1999 income and capital tax treaty with Kuwait took effect on 14 October 2024. The amendment contains new rules for the taxation of dividends,