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Proposed IRC section 899 ‘revenge tax’ targets residents of certain discriminatory/offending foreign countries

On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May 22, 2025 (the House...more

Tax Reform Act Changes to CFC Attribution Rules

The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more

Small Business Credit Availability Act Becomes Law, Allowing BDCs to Incur Significantly More Debt

On March 23, 2018, President Trump signed into law the Consolidated Appropriations Act of 2018, which contains as Title VIII thereof the Small Business Credit Availability Act. ...more

Funds Talk: February 2018

Global Regulators Increasingly Shifting Focus to Cryptocurrency - After years of allowing cryptocurrency transactions to fly under the radar, financial market regulators are beginning to turn their attention to virtual...more

SEC Releases Guidance on Near-Term Disclosure Regarding Effects of New Tax Law

The tax reform signed into law by President Trump on Dec. 22 (the Tax Act) presents public companies with several accounting and disclosure challenges. Although companies are still evaluating how they will be affected by the...more

Tax Reform

On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more

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