OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX -
Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more
On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and...more
7/10/2025
/ Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
SALT ,
Tax Deductions ,
Tax Reform ,
Trump Administration
On July 3, 2025, the House approved the Senate’s legislative text (the “Senate Legislative Version”) for the budget reconciliation bill (H.R. 1, the “One Big Beautiful Bill Act”) without any changes. Thus, the final...more
On June 16, 2025, the US Senate Committee on Finance released its legislative text (the “Senate Finance Committee version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently...more
The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...more
6/19/2025
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Budget Reconciliation ,
Foreign Tax ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Proposed Legislation ,
Public Policy ,
Senate Finance Committee ,
Tax Rates ,
Tax Reform ,
Withholding Tax
Last week, two different district courts found that President Donald Trump did not have the authority under the International Emergency Economic Powers Act (“IEEPA”) to impose sweeping tariffs....more
On May 22, 2025, the House of Representatives passed its reconciliation bill, H.R. 1, entitled “One Big Beautiful Bill Act” (the “legislation”), which significantly amends the clean energy provisions that were enacted as part...more
At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more
On April 2, 2025, President Donald Trump signed an Executive Order designed to address the threat posed to the United States by trade deficits....more
4/9/2025
/ Ad Valorem Tax ,
Aluminum Sales ,
Executive Orders ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Imports ,
Infrastructure ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
Retaliatory Tariffs ,
Section 301 ,
Steel Industry ,
Supply Chain ,
Tariffs ,
Trade Act of 1974 ,
Trade Policy ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
Those in the critical minerals industry have been waiting to see what President Donald Trump’s next move would be after his “Unleashing American Energy” Executive Order on January 20, 2025 (the “January Executive Order”),...more
On March 26, 2025, President Donald Trump signed a proclamation imposing a 25% tariff on imports of automobiles (including passenger vehicles, i.e., sedans, SUVs, crossovers, minivans, cargo vans, and light trucks) and...more
On 12 March 2025, the United States (US) imposed tariffs of up to 25% on imports of steel, aluminium, and certain products containing steel and aluminium from the European Union (EU) and other trading partners....more
Recently, President Donald Trump issued three Executive Orders (EOs) to impose tariffs on Mexico, Canada, and the People’s Republic of China (PRC) pursuant to his authorities under the Constitution and the laws of the United...more
3/10/2025
/ Canada ,
China ,
Constitutional Challenges ,
Executive Orders ,
Exports ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Retaliatory Tariffs ,
Tariffs ,
Trump Administration
On January 7, 2025, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) relating to technology-neutral tax credits for clean energy...more
On January 20, 2025, President Donald Trump signed several executive orders pausing several federal funding streams while the Trump Administration evaluates whether covered government financial assistance aligns with the...more
At A Glance -
The second Trump Administration’s "America First Trade Policy" orders a comprehensive review of US trade and economic policies, focusing on trade deficits, unfair trade practices, and the impact of existing...more
1/28/2025
/ Canada ,
China ,
Export Controls ,
Mexico ,
National Security ,
Section 232 ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
Unfair Competition ,
United States-Mexico-Canada Agreement (USMCA)
On December 4, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations, TD 10015, (the “Final Regulations”), which provide guidance on the definition of energy...more
As global economic and geopolitical environments enter a new era, companies need to continuously develop and adjust their coherent global business strategies to secure and further expand business opportunities in all markets...more
1/2/2025
/ Acquisitions ,
Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Business Opportunities ,
Business Strategies ,
CFIUS ,
China ,
Compliance ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Entity List ,
Exports ,
Final Rules ,
Financial Transactions ,
Forced Labor ,
Foreign Investment ,
Importers ,
Imports ,
Investment ,
Joint Venture ,
National Security ,
NPRM ,
Prohibited Transactions ,
Real Estate Transactions ,
Regulatory Requirements ,
Semiconductors ,
Sensitive Personal Information ,
Supply Chain ,
Trade Relations ,
Uyghur Forced Labor Prevention Act (UFLPA)
On November 14, 2024, the Chairman of the Select Committee on the Chinese Communist Party (“CCP”), John Moolenaar (R-MI), introduced H.R. 10127, the Restoring Trade Fairness Act (the “Legislation"), which would suspend US...more
On October 24, 2024, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) on the Section 45X Advanced Manufacturing Production Credit of the...more
On October 28, 2024, the US Department of the Treasury (“Treasury”) issued a Final Rule to require the notification or prohibition of certain outbound investments and other transactions by US persons involving persons of...more
On July 31, 2024, Senators Jon Ossof (D-GA), Sherrod Brown (D-OH), Bill Cassidy (R-LA), and Rick Scott (R-FL) introduced the bipartisan American Tax Dollars for American Solar Manufacturing Act. The bill aims to “prevent...more
On August 27, 2024, the Office of the U.S. Trade Representative (USTR) published a notice to the Federal Register “invit[ing] written comments from the public concerning the issues raised” by China in its dispute before the...more
As we await the outcome of the upcoming US elections, we know that whoever controls the White House and Congress will confront one of the biggest tax debates in US history in 2025. It is possible that one party wins full...more
While we await the outcome of the upcoming US elections, stakeholders in the energy tax and policy space should recognize that, regardless of the outcome of the election, there will be plenty of activity in the energy sector...more