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
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