On 15 August 2025 the Internal Revenue Service (IRS) released Notice 2025-42 (the Notice), which restricts the methods that developers of wind and solar projects can use to determine whether they have begun construction for...more
President Donald J. Trump signed H.R. 1, the One Big Beautiful Bill Act (OBBBA), into law on 4 July 2025 in an afternoon signing ceremony at the White House (Pub. L. No. 119-21). Senate Majority Leader John Thune (R-SD)...more
7/24/2025
/ Clean Energy ,
Energy Policy ,
Energy Sector ,
Energy Tax Incentives ,
Foreign Entities ,
Investment Tax Credits ,
New Legislation ,
One Big Beautiful Bill Act ,
Renewable Energy ,
Solar Energy ,
Tax Credits ,
Wind Power
On Monday, 16 June 2025, the Senate Finance Committee released its version (the Senate Proposal) of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act” (the Act) that was...more
6/27/2025
/ Budget Reconciliation ,
Cross-Border Transactions ,
Foreign Investment ,
Foreign Tax ,
International Tax Issues ,
Proposed Legislation ,
Retaliatory Tariffs ,
Senate Finance Committee ,
Tax Rates ,
Tax Reform ,
U.S. Treasury
Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more
On 7 October 2020, the Treasury Department and the Internal Revenue Service (IRS) released final regulations under Code Section 1446(f) (the Final Regulations), which clarify aspects of the withholding requirements with...more
Prior to 2017 Tax Cuts and Jobs Act (TCJA), private equity fund, hedge fund, and other investment fund or asset managers that received an interest in an entity taxed as a partnership for U.S. federal income tax purposes (a...more