On 29 January 2026, the Korean National Assembly passed an amendment introducing statutory attorney-client privilege, granting attorneys and clients the right to protect confidential legal communications and related materials. The amendment is expected to meaningfully affect tax audits, investigations, and appeals by offering stronger protection against broad document requests and the use of privileged materials.
On 16 December 2025, the Internal Revenue Service (IRS) issued two Notices addressing reporting obligations for tips and overtime under the Overtime and Bonus-Based Benefits Act (OBBBA).
The guidance provides transition relief for 2025, recognizing that employers and payors may not have updated systems or forms to comply with new requirements. It also explains how taxpayers can calculate deductions for tips and overtime when employer reporting is unavailable.
In addition, the notices signal future mandatory reporting obligations, indicating that structured compliance processes will be introduced in subsequent years.
On 10 December 2025, the IRS and Treasury announced forthcoming proposed regulations to address the sourcing of borrow fees in securities lending and sale-repurchase transactions. The proposed rules will source borrow fees to the residence of the recipient, generally exempting non-US securities lenders from US withholding tax.
The guidance applies to transactions documented under standard industry agreements and defines borrow fees broadly, including negative rebates, while excluding bespoke arrangements.
Taxpayers may rely on the Notice immediately, with the regulations applying prospectively to taxable years ending after publication in the Federal Register
Ukraine’s Defence City regime, effective from October 2025, offers tax, customs, and regulatory incentives to defence-related enterprises. Eligible companies must earn most income from defence goods or services. Benefits include exemptions on reinvested profits, real estate, land, and environmental taxes, plus simplified customs and currency rules. However, it excludes R&D credits and broader investor incentives, and cannot be combined with other preferential regimes. Residency is limited to strategically significant entities approved by the Ministry of Defence.
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.
On July 4, 2025, the One Big, Beautiful Bill Act was signed into law, making important changes to the Internal Revenue Code. The Act has implications for US and non-US companies and their domestic and international transactions, capital investment, and research and development activities, amongst other areas, which carry significant weight for the cryptocurrency/digital asset industry. From cryptocurrency exchanges, payment processors, asset managers and cryptocurrency funds to mining companies, token issuers, custodians, and centralized or decentralized lending platforms, the Act’s provisions reshape the tax landscape in ways that demand close attention.
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.
A new Strategic Goods (Control) Order 2015 (“SGCO 2015”) will replace the current SGCO 2013 with effect from 2 November 2015. According to Singapore Customs, the SGCO 2015 brings Singapore’s strategic goods control list up to date with the 2014 Wassenaar Arrangement Munitions List and the 2014 European Union’s List of Dual-Use Items.
On 9 October 2014, the new Belgian federal government announced, in its coalition agreement for the coming term, its intention to introduce a regime of tax transparency for the income of trusts and other foreign legal arrangements (the so-called Cayman Tax).