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Rafic H. Barrage on Muck Rack

Rafic H. Barrage

As seen in: Bloomberg Law, Lexology, Bloomberg Tax, Global Compliance News
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Articles

How the OBBBA’s International Tax Rule Changes Impact MNEs Original

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By Julia Ushakova-Stein, Rafic H. Barrage, Katie Rimpfel
| Bloomberg Tax Verified
The now-enacted international tax reforms in the One Big Beautiful Bill Act (OBBBA or Act) have important implications for multinational enterprises (MNEs). In the early days of the reconciliation process, as Congress weighed the budgetary effects of extending the sunsetting provisions of the Tax Cuts and Jobs Act, international tax practitioners had little reason to expect substantial reforms to the US international tax regime.
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United States: A Closer Look at How Proposed Section 899 Would Increase Tax Rates for Certain Non-US Persons and Governments

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By Rafic H. Barrage, Ethan Kroll, Kathryn Rimpfel, Scott Levine
| Lexology Verified
On May 22, 2025, the House passed the One Big Beautiful Bill Act of 2025 as modified by the manager's amendment from the Rules Committee. No modifications were made to the retaliatory tax provision in proposed section 899, which has garnered interest from US inbound companies.
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Digital Content, Cloud Rules See Mostly Clear Skies Ahead: Part 2 Original

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By Rafic H. Barrage, Gary Sprague, Erik J. Christenson, Steven Smith
| Bloomberg Tax Verified
In Part 1, we discussed the “Final Regulations” (T.D. 10022, comprised of the “Final Digital Content Regulations” and “Final Cloud Regulations”), released by Treasury and the IRS on January 10, 2025. We now turn to the proposed regulations under Reg. §1.861-19(d), relating to the source of income from cloud transactions (the “Proposed Cloud Sourcing Regulations”) (REG-107420-24, 90 Fed. Reg. 3,075 (Jan.
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