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Cross-Border Transactions U.S. Treasury

Eversheds Sutherland (US) LLP

Tax Bytes: Week of September 1, 2025

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

Eversheds Sutherland (US) LLP

IRS and Treasury notice proposes removal of disregarded payment loss rules and changes to dual consolidated loss rules

On August 20, 2025, the Internal Revenue Service (IRS) released Notice 2025-44 (Notice), which announced that the Department of the Treasury (Treasury) and IRS intend to issue proposed regulations that would...more

Morgan Lewis

CFIUS Annual Report for 2024: Key Trends in Filings, Mitigation, and Enforcement

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The Committee on Foreign Investment in the United States (CFIUS or the Committee) has released its Annual Report to Congress for calendar year 2024. As with earlier years, the report provides detailed statistics on CFIUS’s...more

Wiley Rein LLP

CFIUS 2024 Annual Report: Compliance, Enforcement, and Non‑Notified Transactions – What Dealmakers Need to Know

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The Committee on Foreign Investment in the United States (CFIUS) recently released the public version of its Annual Report to Congress for calendar year 2024. Key trends include an increase in formal inquiries into...more

Cadwalader, Wickersham & Taft LLP

New Lessons in Regulation, August 2025 - FinCEN Extends Effectiveness Date of Orders Targeting CIBanco, Intercam, and Vector until...

Parties have an additional six weeks to prepare for the impact of FinCEN’s June 25, 2025 orders targeting three Mexican financial institutions. On August 19, 2025, FinCEN extended the effectiveness date of three orders...more

Lowenstein Sandler LLP

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

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Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...more

K&L Gates LLP

Senate Updates Code Section 899

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On Monday, 16 June 2025, the Senate Finance Committee released its version (the Senate Proposal) of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act” (the Act) that was...more

Hogan Lovells

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

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The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

Seward & Kissel LLP

July 31 Deadline for BE-180 Reports

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The BE-180 is the quinquennial Benchmark Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign Persons (the “BE-180 Survey”) conducted by the U.S. Bureau of Economic Analysis (the...more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

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Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more

Blank Rome LLP

Navigating New Compliance Challenges for Financial Institutions and Payment Processors: The U.S. Treasury’s Enhanced Terrorist...

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In a significant move to combat illicit financial activities focused on cartels, the U.S. government has intensified its scrutiny of cross-border payments, particularly those linked to Mexico. This development follows the...more

The Volkov Law Group

OFAC Designates Gazprombank for Inclusion on SDN List

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In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a...more

Wilson Sonsini Goodrich & Rosati

The New National Security Rules for Investing U.S. Capital

A Guide to the New Diligence Questions for “Outbound” U.S. Investment - In late October 2024, the U.S. Treasury Department (Treasury) issued its final rules (the Outbound Rules) implementing President Biden’s Executive Order...more

Parker Poe Adams & Bernstein LLP

How Overseas Investors Can Navigate Broad Reach of Federal Government's CFIUS Real Estate Reviews in the Carolinas

There are more than 500 miles that separate the western, more mountainous region of North Carolina from the U.S. state’s eastern shorelines. It’s an expansive area that, depending on traffic, can take close to 9 hours to...more

Holland & Knight LLP

Treasury Department Launches New CFIUS Enforcement Website

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The Committee on Foreign Investment in the United States (CFIUS or Committee) on Aug. 14, 2024, announced its largest-ever enforcement action and launched a new section of its website dedicated to enforcement. In addition to...more

Cadwalader, Wickersham & Taft LLP

Treasury Finalizes “Killer B” Regulations with Few Adjustments

On July 17, the U.S. Treasury and IRS released final regulations targeting various inbound cross-border transactions broadly referred to as “Killer B” transactions, marking the end (for now) of a long-running regulatory fight...more

Morgan Lewis

Treasury Proposes Rule to Expand CFIUS’s Real Estate Jurisdiction

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The US Department of the Treasury on July 8, 2024 proposed updates to the Committee on Foreign Investment in the United States’s (CFIUS’s) regulations that seek to expand the list of military installations for which proximity...more

Cadwalader, Wickersham & Taft LLP

Treasury Proposes Enhancing CFIUS Enforcement Authority

On April 11, 2024, the U.S. Department of the Treasury announced a notice of proposed rulemaking that would expand the enforcement authority of the Committee on Foreign Investment in the United States (“CFIUS” or the...more

Jones Day

New Guidance from the Treasury Department on 1% Corporate Stock Buyback Tax

Jones Day on

On April 9, 2024, the U.S. Treasury Department ("Treasury") issued proposed regulations and reporting requirements providing further guidance on the non-deductible 1% excise tax that was enacted on August 16, 2022 (as Section...more

Fox Rothschild LLP

The Role of National Security in the U.S.-China Battle Over Foreign Direct Investment

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As the People’s Republic of China (PRC) has emerged as a major economic power and competitor, the U.S. has leaned heavily on and enhanced its foreign direct investment regime over recent years to protect its national security...more

Fox Rothschild LLP

Biden Restricts Outbound Technology Investments into China

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A recent executive order issued by President Biden aims to prohibit or oversee investments in certain sensitive technologies that could threaten the national security of the United States. The executive order, which was...more

Seyfarth Shaw LLP

Long-Awaited Outbound Investment Program Finally Addressed

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On August 9, 2023, President Biden issued an Executive Order entitled, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the “EO”), declaring a national...more

Wilson Sonsini Goodrich & Rosati

Biden Unveils Executive Order: Outbound Screening Program Restricting China Investments

In one of the most highly anticipated moves in recent U.S.-China relations, President Biden issued an Executive Order on August 9, 2023 (the EO), declaring a national emergency and restricting certain types of outbound...more

Fenwick & West LLP

Biden Administration Unveils Proposed Outbound Investment Restrictions Targeting Chinese Advanced Technology Companies

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On August 9, President Biden issued an executive order (E.O.) directing the U.S. Department of the Treasury (Treasury), in consultation with the U.S. Department of Commerce and other U.S. agencies, to adopt regulations that...more

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