The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more
The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
This bulletin follows our previous update on evolving U.S. tax reform, which highlighted the competing House and Senate proposals, particularly the introduction and scope of proposed Section 899 targeting "unfair foreign...more
With a name like the One Big Beautiful Bill Act (OBBBA), you know two things right away: (1) it’s a mouthful, and (2) you’re going to have to wade through a lot to find the useful parts. Fortunately, two tax lawyers already...more
On July 3, 2025, the U.S. Congress passed H.R. 1, “An Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14” (the “Act”). The Act was signed into law on July 4, 2025. The House of Representatives passed...more
On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance...more
The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more
The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more
Key Points - - The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent. - The bill...more
On June 16, 2025, the Senate Finance Committee released proposed text for tax provisions to be included in the Senate’s version of the One Big Beautiful Bill Act (OBBB). Our prior Alert addresses the House version of the...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more
The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more
On Friday, May 9, the House Ways and Means Committee shared partial text for the tax portion of a reconciliation bill to extend the 2017 Tax Cuts and Jobs Act (TCJA) and make certain other tax reforms. The bill includes...more
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
On June 22, 2023, the US Senate passed a resolution consenting to the ratification of the Income Tax Treaty between Chile and the United States (Treaty). The resolution opens the door for President Biden to formally ratify...more
Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more
In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more
The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more
Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the...more
On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is...more
On March 31, 2021, President Biden presented an infrastructure spending plan coupled with a tax reform plan that seeks to raise corporate income taxes (the “American Jobs Plan” and the “Made in America Tax Plan”). The...more
Our International Tax Group elaborates on the final regulations recently issued by the IRS and Treasury on the base erosion and anti-abuse tax (BEAT)....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of...more