The following is part of our annual publication Selected Issues for Boards of Directors in 2026. Explore all topics or download the PDF.


The international tax landscape is increasingly fractured. Boards of multinational companies may want to pay particular attention to the impact of and ongoing developments with respect to (i) the OECD’s Base Erosion and Profit Shifting (BEPS) Pillar Two rules, and (ii) the “One Big Beautiful Bill Act” (OBBBA).Continue Reading Significant Tax Measures Remain in Flux for Large Multinational Groups

The following post was originally included as part of our recently published memorandum “Selected Issues for Boards of Directors in 2020”.

The international tax system is continuing to experience a period of significant change, as taxing authorities across the globe are continuing to adopt and implement new rules and procedures to respond to

Under proposed regulations issued yesterday (October 31), U.S. multinationals would generally be relieved from the “Section 956 deemed dividend rules” that have significantly limited their ability to provide lenders with credit support (for example, in the form of guarantees and collateral) from their non-U.S. subsidiaries. In general, under the proposed regulations, the credit packages provided