International Tax Developments

• May 20, 2024, R&D Credit and International Tax Planning
• April 29, 2024, Tax Court Decisions, Guidance, and the Continuing Evolution of Regulatory Invalidity
• March 25, 2024, Tax Planning for Licensing and Collaboration Agreements by Life Sciences Companies
• January 22, 2024, Section 987 Regulations: The Good, the Bad, and the Ugly

• December 11, 2023, Fenwick's 2023 Tax Wrap-Up Extravaganza
• October 30, 2023, Strategic Tax Planning Around Divestiture and Carve-Out Transactions
• August 14, 2023, Economic Substance: Trends in IRS Enforcement and Implications for Planning
• July 6, 2023, Section 965 and the Moore Case: What you need to think about now
• June 20, 2023, Privilege: What You Do Now Can Help You Win Later
• May 22, 2023, GILTI Boot Camp
• April 24, 2023, How to Prepare for Pillar Two
• March 13, 2023, Transfer Pricing Update
• January 23, 2023, Recent International Tax Developments: IRS Year-End Notices and EU Pillar Two Directive

• December 13, 2022, Fenwick’s 2022 Tax Wrap-Up Extravaganza
• November 14, 2022, Tax Considerations of the Strong Dollar and FX Volatility
• August 25, 2022, Inflation Reduction Act’s Corporate Minimum Tax & Stock Buyback Tax: How They Affect You
• July 18, 2022, Crypto & Blockchain: What Every Tax Department Needs To Know
• May 2, 2022, International Tax Updates - A Round-Up of Recent Cases and PLRs with International Tax Implications
• March 7, 2022, Foreign Tax Credit Regulations, Part II
  
• February 7, 2022, Foreign Tax Credit Regulations, Part I

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• December 13, 2021, International Tax Year in Review
• October 6, 2021, The House Ways & Means Bill
• August 30, 2021, Foreign Tax Credit Issues
  
• July 19, 2021, Recent International Tax Developments
  
• May 20, 2021, Foreign Disregarded Entities After TCJA
• April 12, 2021, International Partnerships After TCJA
• March 8, 2021, Tax Compliance and Planning Issues Involving Debt
• February 8, 2021, Transfer Pricing Insights

• December 7, 2020, International Tax M&A Update
• November 16, 2020, Foreign Tax Credit Regulations
• October 26, 2020, Litigating Tax Disputes in a 2020s Legal Landscape
• September 21, 2020, Loss Planning and GILTI HTE
• August 17, 2020, FDII Final Regulations
• July 21, 2020, Foreign Branches – Planning Issues and Traps for the Unwary
• April 27, 2020, Latest U.S. International Tax Developments and Planning

Fenwick Published

• April 12, 2022, Important Subpart F and PFIC Changes for U.S. Investors and Domestic Funds
• January 31, 2022, Treasury Finalizes Foreign Tax Credit Regulations, Including Novel Jurisdictional Nexus (Attribution) Rule

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• May 2, 2022, Tax Notes International, Section 245A Regs, The Green Book, and Crypto Reporting
• April 4, 2022, Tax Notes International, GLOBE and Nexus Rules, Final FTC Reg Comments, and Priority Guidance Plan Updates
• March 7, 2022, Tax Notes International, Final Subpart F and Proposed PFIC Regs
• February 21, 2022, Tax Notes International, Transfer Pricing, Pillar 2, And the Build Back Better Act
• February 7, 2022, Tax Notes International, 2022 Final Regulations
• January 31, 2022, Tax Notes International, Final Foreign Tax Credit Regulations
• January 3, 2022, Tax Notes International, Whirlpool, Coca-Cola, FTC Regs, DST Agreements, and Global Tax Reform

Fenwick Published

• December 1, 2021, International Tax Journal, Recent Private Rulings of Interest
• September 9, 2021, US Tax Legislation Alert: Wyden Bill Proposes Major Changes to GILTI, Foreign Tax Credit and Other Rules
• August 16, 2021, Senate Passes Infrastructure Bill Including Language on Digital Assets and Reporting of Crypto Transactions
• August 16, 2021, International Tax Review, Biden Tax Plan Alters M&A Outlook
• August 11, 2021, Section 987 Practice Unit Reflects a Permissive Attitude Towards Different Methods of Branch Currency Translation
• June 17, 2021, Debt Push Downs and the Curious Application of the Debt-Netting Rule
• March 9, 2021, A Virtuous Cycle: Investing in Diversity and Inclusion
• February 25, 2021, PFIC Testing—Significant New Guidance but Some Unanswered Questions Remain
• January 14, 2021, IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers for 2021

Subscription Required

• December 6, 2021, Tax Notes International, The Build Back Better Act
• November 1, 2021, Tax Notes International, Pillars 1 and 2, FTC Regs, and Eaton
• October 4, 2021, Tax Notes International, International Tax Reform Proposals and FTC Guidance
• September, 6, 2021, Tax Notes International, Branch Currency Transactions, FDII, and OECD Update
• August 2, 2021, Tax Notes International, International Tax Reform, Reverse Clawbacks, and GILTI
• July 5, 2021, Tax Notes International, International Tax Reform, Coca-Cola, Medtronic, and IRS's Entity Classification Election Ruling
• June 7, 2021, Tax Notes International, The Biden Tax Plan, CFC Accounting Method Change, and Amazon
• May 3, 2021, Tax Notes International, The Biden Tax Plan, APAs, and Entity Classification
• April 5, 2021, Tax Notes International, Multinational and Foreign Corporations, Partnership Interest Sales, and IRS Letter Rulings
• March 8, 2021, Tax Notes International, A Virtuous Cycle: Investing in Diversity and Inclusion
• March 1, 2021, Tax Notes International, Comments on FTC Proposed Regs
• February 1, 2021, Tax Notes International, Final Section 163(j) Regulations
• February 12, 2021, Tax Notes International, Final and Proposed PFIC Regs
• January 29, 2021, Tax Notes International, Coca-Cola, Proposed GILTI and FDII Regs, and Final Section 245A and PFIC Regs