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

Panama introduced a tax amnesty through Law 446, published in the Official Gazette on 28 October 2024, offering tax relief on surcharges and late interest payments for various tax liabilities, such as income tax, real estate tax, VAT, selective

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