In the context of mergers and acquisitions (M&A), Tax is often under the spotlight during the period leading up to a deal signing. During this time, due diligence is conducted, a step plan is developed outlining steps required to complete the…

As an update, the Monetary Authority of Singapore (MAS) has provided further information regarding the new financial sector incentives (“FSI”) announced during 2025 Budget Statement in the MAS Circular released on 3 July 2025 [1]. The FSI will now…

On June 9, 2025, the IRS released Rev. Proc. 2025-23,[1] which updates the list of accounting method changes — previously in Rev. Proc. 2024-23 — that qualify for the automatic change procedures under Rev. Proc. 2015-13.The updated revenue…

As the Republican’s self-imposed July 4th deadline for the One Big Beautiful Bill Act (“OBBBA”) nears, attention is focused on the Senate Parliamentarian, who is determining which provisions procedurally can be included in a reconciliation bill,…

On Monday, Senator Crapo released much-anticipated initial draft legislation from the Senate Finance Committee for the One Big Beautiful Bill Act reconciliation bill (the Senate Bill). This release marks a pivotal step in the ongoing legislative…

On May 22, 2025, the House passed H.R. 1 (the "House Bill").[1]  While the House Bill generally focuses on domestic taxpayers, it includes section 899, "Enforcement Remedies Against Unfair Foreign Taxes," which, if enacted, could dramatically…

One hundred and twenty-two days after President Trump was sworn into office, the House Republicans advanced the One Big Beautiful Bill Act reconciliation bill  [1] (the House Bill). As articulated in our prior alert, we were anticipating a…

As part of the budget reconciliation plan[1], the House of Representatives are proposing a significant expansion[2] of Public Law 86-272[3], a statute that has provided crucial tax protections for out-of-state businesses since its enactment in 1959…