Calvin Lee at Cooley LLP

Key International Tax Provisions Under the One Big Beautiful Bill Act

On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. It is a landmark piece of legislation that introduces several important changes to the US international tax regime. This alert provides an overview...more

7/22/2025 / Base Erosion and Anti-Abuse Tax (BEAT) , CFC , Corporate Taxes , Foreign Corporations , GILTI tax , International Tax Issues , Tax Credits , Tax Deductions , Tax Legislation , Tax Reform

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

7/1/2025 / Corporate Taxes , Government Agencies , Income Taxes , International Tax Issues , International Trade , New Legislation , OECD , Proposed Legislation , Tax Rates , U.S. Treasury

Soroban: An Update After US Tax Court Ruling

On May 28, 2025, the US Tax Court ruled that investment manager limited partners in Soroban Capital Partners were active limited partners and, as such, were ineligible for the limited partner exception to self-employment...more

6/6/2025 / Appeals , Internal Revenue Code (IRC) , Investment Management , Limited Partnerships , Partnerships , Self-Employment Tax , Tax Court , Tax Liability

IRS Publishes Proposed Regulations on Stock Buyback Excise Tax

On April 12, 2024, the US Department of the Treasury and the IRS published proposed regulations (89 FR 25980 and 89 FR 25829, the “Proposed Regulations”) on the application of Section 4501, which imposes a 1% excise tax on...more

5/1/2024 / Excise Tax , IRS , Proposed Regulation , Share Buybacks , Stock Repurchases , Tax Liability

IRS Announces Voluntary Disclosure Program for Erroneously Received Employee Retention Credits

On December 21, 2023, the IRS announced (IR-2023-247) a voluntary disclosure program for employers to return payments received in respect of erroneously submitted ERC claims. The IRS also provided a list of frequently asked...more

1/2/2024 / Eligibility , Employee Retention , IRS , Tax Credits , Voluntary Disclosure

IRS Announces Withdrawal Process for Employee Retention Credit Claims

On October 19, 2023, the IRS announced (IR-2023-193) a withdrawal process for Employee Retention Credit (ERC) claims. The ERC withdrawal procedure follows an earlier IRS announcement (2023-169) on September 14, 2023, of an...more

10/27/2023 / Employee Retention , IRS , Tax Credits

IRS Announces Moratorium on Processing New Claims for Employee Retention Credit

On September 14, 2023, the IRS announced an immediate moratorium on processing new claims for the Employee Retention Credit (ERC). According to the IRS announcement (IR-2023-169), the moratorium will last through at least the...more

9/22/2023 / Coronavirus/COVID-19 , Employee Retention , Internal Revenue Code (IRC) , IRS , Tax Credits

Interim Guidance on Stock Buyback Excise Tax Confirms Broad Application to M&A and Capital Market Transactions

The Inflation Reduction Act imposes a 1% excise tax on certain repurchases of stock of publicly traded US corporations (“Covered Corporations”) effected after December 31, 2022 (the “Excise Tax”). On December 27, 2022, the...more

1/19/2023 / Acquisitions , Excise Tax , Mergers , Share Buybacks

Did the Inflation Reduction Act Create a SPAC Tax?

On August 16, 2022, House Resolution 5376, the Inflation Reduction Act (IRA), was signed into law. An August 11 Cooley client alert explains some of the tax provisions contained in the IRA, including the 1% excise tax on...more

9/26/2022 / Excise Tax , Inflation Reduction Act (IRA) , Shareholders , Special Purpose Acquisition Companies (SPACs) , Stock Repurchases

Calvin Lee

Cooley LLP

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