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 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
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
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
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
On September 1, 2020, the Treasury Department and the Internal Revenue Service (IRS) issued final regulations in T.D. 9910 (the “Regulations”) permitting taxpayers to waive deductions to reduce or eliminate liability for the...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more