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
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
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
FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more