In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
6/11/2025
/ Banks ,
Borrowers ,
Consumer Financial Products ,
Corporate Taxes ,
Federal Budget ,
Financial Institutions ,
Financial Services Industry ,
Foreign Banks ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Loans ,
Regulatory Requirements ,
Tax Liability ,
Trump Administration ,
Withholding Tax
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
6/2/2025
/ Banks ,
Borrowers ,
Consumer Financial Products ,
Consumer Lenders ,
Federal Budget ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Foreign Investment ,
Income Taxes ,
Interest Payments ,
International Tax Issues ,
Lenders ,
Loans ,
Pending Legislation ,
Proposed Legislation ,
Regulatory Agenda ,
Tax Liability ,
Tax Reform ,
Trump Administration ,
Withholding Tax
Last week, President Trump signed H.R. 1 (New Act), the new tax bill amending the Internal Revenue Code to reduce tax rates, modify policies, credits, and deductions for individuals and businesses “to provide for...more
The amendments may cause some uncertainty and anxiety for U.S. investors as they consider how these changes will impact business, income, profitability and the benefits or drawbacks of investing in India through Mauritius....more
10/6/2016
/ Acquisitions ,
Capital Gains ,
Double Taxation ,
Foreign Direct Investment ,
India ,
International Tax Issues ,
Investors ,
Mauritius ,
Popular ,
Tax Exemptions ,
Tax Rates ,
Tax Treaty ,
Withholding Tax
As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more
5/12/2015
/ Cross-Border Transactions ,
FATCA ,
Foreign Taxpayers ,
International Tax Issues ,
OECD ,
Subpart F ,
Tax Credits ,
Tax Planning ,
Tax Policy ,
Tax Reform ,
Transfer Pricing
In this Presentation:
- Topics
- Inversion
- Inversions – How Did We Get Here?
- Impact Of The §367 Regulations
- 2003 – Enactment of §7874
- §7874
- Determining “Ownership”
- Treasury Regulation...more