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Summary of key provisions in House reconciliation bill

On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Proposed dual consolidated loss regulations would disallow U.S. tax use of foreign losses viewed as reducing Pillar Two tax...

On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503 (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the...more

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