Tax News and Developments July 2025 In brief The recently enacted reconciliation bill (the One Big Beautiful Bill Act or OBBBA) creates several new provisions that, depending on the right facts, can make domestic business more attractive. The OBBBA includes provisions that provide relief from US tax liability in the form…
The One Big Beautiful Bill Act makes three major changes to the interest deduction limitation provision of §163(j). Pub. L. No. 119-21, §70303, §70341 (July 4, 2025), applicable to taxable years beginning after December 31, 2024. This article reviews the three changes and then focuses on the new rule for capitalized interest.
China has introduced a new tax reporting regime requiring internet platforms—both domestic and overseas—to regularly report tax-related information to Chinese authorities. This move, under State Council Decree No. 810 and STA Bulletin [2025] No. 15, aims to close tax loopholes and enforce compliance. Platforms must now implement robust systems to meet these obligations, with significant implications for data privacy and cross-border data transfers.
As of 18 February 2025, the US Treasury’s Financial Crimes Enforcement Network is once again authorized to enforce the beneficial owner interest (BOI) reporting provisions of the Corporate Transparency Act . Therefore, beneficial ownership interest report filing by Reporting Companies is once again mandatory with an extended deadline of March 21, 2025, for many companies.
On 20 December 2024, the Hong Kong government gazetted the Companies (Amendment) (No.2) Bill 2024 (“Bill”) which introduces Hong Kong’s long awaited inward re-domiciliation regime. The Bill was introduced to the Legislative Council on 8 January 2025 and once enacted, will enable non-Hong Kong incorporated companies to relocate their domicile to Hong Kong, while maintaining their legal identity and business continuity.
The IRS recently announced changes to its Form 14457, “Voluntary Disclosure Practice Preclearance and Application,” which allows taxpayers to apply to the IRS in an attempt to limit criminal exposure by disclosing past noncompliance and paying past taxes, interest and penalties. The new form includes several revisions that demonstrate a stricter approach towards taxpayers wanting to voluntarily disclose past tax-related misconduct, including: an admission of willfulness, a more detailed narrative requirement, a shorter time to prepare documents, and mandatory full payment. Taxpayers should consult with counsel to examine any increased risks associated with filing the revised form.
Tax News and Developments September 2024 In brief Many litigants argue that FBAR penalties, which can exceed the value of the unreported foreign accounts, violate the excessive fines clause of the Eighth Amendment. Courts have routinely held that the Eighth Amendment does not apply in this situation. However, the Eleventh…
On 26 September 2024, the OECD Inclusive Framework published a Model Competent Authority Agreement to assist jurisdictions that have implemented the simplified and streamlined approach under Amount B to provide tax certainty. The MCAA is mainly intended to be applied in relation to Covered Jurisdictions as defined in the 17 June 2024 guidance. However, the OECD notes that Inclusive Framework members may use the MCAA as a model for negotiations with jurisdictions that are not defined as Covered Jurisdictions. This workstream has remained pending since the release of the guidance reports in February and June 2024. Therefore, the MCAA brings Amount B one step further toward completion and political agreement, in light of the envisaged local implementation commencing in fiscal years beginning after 1 January 2025.
On 2 August 2024, Bill No. 2308/2023, which establishes the legal framework for low-carbon hydrogen in Brazil, was approved with a partial veto. Numbered as Law 14948/2024, it has created the National Low-Carbon Hydrogen Policy, which will form part of the country’s National Energy Policy. The Law has also established the competence of the National Agency for Oil, Natural Gas and Biofuels to authorize, regulate and inspect activities in the low-carbon hydrogen value chain, and has created the Brazilian Hydrogen Certification System and the Special Incentive Regime for Low-Carbon Hydrogen Production, a tax regime designed to foster technological and industrial development, competitiveness and added value in national production chains.
The new disregarded payment loss rules could create material, adverse tax consequences for taxpayers that make check-the-box elections for foreign disregarded entities within a US consolidated group (or otherwise form new foreign disregarded entities). As a result, taxpayers should assess their exposure under the disregarded payment loss rules before making any such elections or forming such entities within the US consolidated group.