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Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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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

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

Troutman Pepper Locke on

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

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment formula for financial institutions, aiming to increase tax revenue starting in tax year 2025. Update: On May 14, 2025, Governor Newsom released the May...more

Pillsbury Winthrop Shaw Pittman LLP

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

Stoel Rives LLP

Estate Planning and Income Tax Updates You Need to Know

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Tax filing deadline. The Internal Revenue Service has issued Notice 2020-18 extending both the federal income tax filing and payment due dates for 2019 income tax returns from April 15, 2020 to July 15, 2020. These extensions...more

Ballard Spahr LLP

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

Ballard Spahr LLP on

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

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