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
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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
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International Tax Issues ,
Lenders ,
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Pending Legislation ,
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Withholding Tax
The various forms of information reporting required by the Internal Revenue Code form the backbone of both voluntary compliance with tax laws and the starting point for audits by the Internal Revenue Service (IRS). One form...more
4/17/2024
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Dispensaries ,
Fifth Amendment ,
Internal Revenue Code (IRC) ,
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Tax Liability
In Notice 2020-18, released on March 25, the Department of the Treasury announced that any person with a federal income tax payment or federal income tax return due on April 15, 2020 has until July 15, 2020 to make the...more
The U.S. federal taxation of non-U.S. persons who transfer interests in partnerships has a long and storied history. The government staked out its position in 1991, effectively providing that a non-U.S. partner should be...more
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes.
Do you have responsibility, whether direct or dotted line, for the tax function in your...more