On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more
6/9/2025
/ Foreign Corporations ,
Foreign Investment ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Investors ,
IRS ,
New Regulations ,
Proposed Legislation ,
Taxation ,
U.S. Treasury
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
2/24/2025
/ Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Repeal ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
U.S. Commerce Department