Weil Tax BLOG - Feed https://tax.weil.com/contributor/devon-bodoh/ Views and developments from the Tax Department at Weil Fri, 04 Sep 2026 18:19:37 +0000 hourly 1 Proposed Treasury Regulations Implement OBBBA Changes to CFC Pro Rata Share Rules for Subpart F Income, Tested Income, or Tested Loss https://tax.weil.com/insights/proposed-treasury-regulations-implement-obbba-changes-to-cfc-pro-rata-share-rules-for-subpart-f-income-tested-income-or-tested-loss/ Wed, 26 Aug 2026 20:30:17 +0000 Devon Bodoh Stephanie Galvis George Vallejo https://tax.weil.com/?p=2689 On August 26, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations (REG-115646-25) under Sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s (“CFC”) subpart F income (as defined in Section 952 of the Code), tested income, or tested

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]]> On August 26, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published proposed regulations (REG-115646-25) under Sections 951 and 951A addressing the determination of a U.S. shareholder’s pro rata share of a controlled foreign corporation’s (“CFC”) subpart F income (as defined in Section 952 of the Code), tested income, or tested

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]]> Proposed Treasury Regulations Clarify Scope of Section 250 Exclusion for Certain Property Dispositions https://tax.weil.com/insights/proposed-treasury-regulations-clarify-scope-of-section-250-exclusion-for-certain-property-dispositions/ Fri, 21 Aug 2026 21:23:12 +0000 Devon Bodoh Zachary Torres George Vallejo https://tax.weil.com/?p=2684 On August 20, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117130-25) under Section 250 addressing the treatment of certain sales and other dispositions of property for purposes of determining foreign-derived deduction eligible income (“FDDEI”) (the “Proposed Regulations”).1 The Proposed Regulations clarify the scope of the exclusions from

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]]> On August 20, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117130-25) under Section 250 addressing the treatment of certain sales and other dispositions of property for purposes of determining foreign-derived deduction eligible income (“FDDEI”) (the “Proposed Regulations”).1 The Proposed Regulations clarify the scope of the exclusions from

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]]> Tax in Distressed Situations https://tax.weil.com/insights/tax-in-distressed-situations-2/ Fri, 20 Mar 2026 15:41:37 +0000 Devon Bodoh Joseph Pari Edouard de Lamy Oliver Walker Stuart Pibworth https://tax.weil.com/?p=2632 Following the launch of the Tax in Distressed Situations microsite, created in collaboration with Loyens & Loeff, in 2025, our global Tax teams and Loyens have published seven updated jurisdictional guides on the topic. The updated guides reflect market trends over the last year as well as a new section addressing Pillar 2 considerations in

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]]> Following the launch of the Tax in Distressed Situations microsite, created in collaboration with Loyens & Loeff, in 2025, our global Tax teams and Loyens have published seven updated jurisdictional guides on the topic. The updated guides reflect market trends over the last year as well as a new section addressing Pillar 2 considerations in

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]]> International Comparative Legal Guide (ICLG) – USA: Corporate Tax Laws and Regulations 2026 https://tax.weil.com/latest-thinking/international-comparative-legal-guide-iclg-usa-corporate-tax-laws-and-regulations-2026/ Thu, 18 Dec 2025 19:27:07 +0000 Devon Bodoh Joseph Pari Blake Bitter https://tax.weil.com/?p=2598 In this chapter, we provide an overview of Tax laws and regulations applicable in the U.S. View our chapter here. *This chapter first appeared in the International Comparative Legal Guide (ICLG) – Corporate Tax 2026

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]]> IRS Issues Final and Proposed Regulations Clarifying Section 892 Exemption for Foreign Government Investors https://tax.weil.com/latest-thinking/irs-issues-final-and-proposed-regulations-clarifying-section-892-exemption-for-foreign-government-investors/ Thu, 18 Dec 2025 17:28:44 +0000 Devon Bodoh Isabela Cantarelli https://tax.weil.com/?p=2595 On December 12, 2025, the Internal Revenue Service (“IRS”) released final regulations under Section 892 of the Internal Revenue Code (TD 10042), together with proposed regulations (REG-101952-24), addressing when a foreign government or their controlled entities is treated as engaged in commercial activity (and certain other matters relating to the application of Section 892). The

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]]> Weil Tax Insight Series: The One, Big, Beautiful Bill Act: The Future of Tax Policy? https://tax.weil.com/insights/weil-tax-insight-series-the-one-big-beautiful-bill-act-the-future-of-tax-policy/ Tue, 08 Jul 2025 21:35:35 +0000 Joseph Pari Devon Bodoh https://tax.weil.com/?p=2551 After much debate on Capitol Hill, President Trump signed into law the One, Big, Beautiful Bill Act (the “Bill”) on July 4, 2025, delivering a sweeping legislative tax and spending package. In this edition of the Weil Tax Insight Series, Tax Head Joe Pari and International Tax Head Devon Bodoh discuss key provisions covered by

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