José Germano Rego

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Articles

Treasury And The IRS Proposed Regulations On Previously Taxed Earnings And Profits

Dec 4, 2024 | mondaq.com | Larry Crouch |Ryan Bray |Matthew Brown |José Germano Rego |José Márcio Rêgo

AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.
Invest in Your Future: The Best UX Black Friday Deal You’ll Find This Year

Nov 22, 2024 | medium.com | José Germano Rego |José Márcio Rêgo

Jose Rego·Follow3 min read·--Black Friday isn’t just for gadgets and fashion — it’s also the perfect time to invest in yourself. If you’ve been considering building or sharpening your UX design skills, this year’s Black Friday offer from Uxcel is a deal worth exploring. Save 62.5% on Uxcel Pro!To ensure my stories are clear and engaging for everyone, I use AI tools to help edit and refine my writing.
Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax liabilities

Aug 12, 2024 | lexology.com | Larry Crouch |Ryan Bray |Jay Singer |Matthew Brown |José Germano Rego |José Márcio Rêgo

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503[1] (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the Global Anti-Base Erosion Rules (Pillar Two) (“Pillar Two Rules”),[2] among other DCL issues.[3] If finalized, the Proposed Regulations would increase the relevance of the DCL rules for many U.S. consolidated groups with foreign affiliates either above or below such U.S....
U.S.-Chile Income Tax Treaty Enters Into Force

Dec 28, 2023 | lexology.com | Larry Crouch |Ryan Bray |Todd Lowther |Jay Singer |Matthew Brown |José Germano Rego | +1 more

On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”).[1] The Treaty provides for reduced withholding tax rates on income such as dividends, interest and royalties with the goal of reducing double taxation and increasing commerce and investment between the United States and Chile.