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Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

Kelley Drye & Warren LLP on

The One Big Beautiful Bill Act (the ​“Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

Seyfarth Shaw LLP

Hong Kong Launches Company Re-domiciliation Regime

Seyfarth Shaw LLP on

In a move to enhance Hong Kong’s status as a global business and financial hub, and to attract foreign companies to take advantage of Hong Kong’s taxation system and professional services–thereby encouraging investment and...more

Seward & Kissel LLP

Should you call 911 about Section 899?

Seward & Kissel LLP on

On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

McDermott Will & Schulte

The Proposed US Tax Regime for Non-US Investors and Companies

McDermott Will & Schulte on

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Allen Barron, Inc.

Foreign Corporate Ownership and Investments

Allen Barron, Inc. on

Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more

White & Case LLP

Luxembourg Tax Update: Key Takeaways from Prime Minister Luc Frieden’s State of the Nation Address

White & Case LLP on

In his State of the Nation Address on June 11, 2024, Luxembourg Prime Minister Luc Frieden introduced several significant fiscal policy initiatives aimed at enhancing the country’s attractiveness to international businesses...more

Holland & Knight LLP

Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses

Holland & Knight LLP on

The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more

A&O Shearman

Briefing Note on UAE Economic Substance Regulations

A&O Shearman on

Cabinet resolution number 31 of 2019 concerning economic substance requirements was recently published on the Ministry of Finance website. The issuance of this resolution requires companies operating a ‘relevant activity’ in...more

Holland & Knight LLP

El Decreto 1415 de 2018 Modifica Parcialmente el Decreto 1625 de 2016

Holland & Knight LLP on

Por considerarlo de su interés les informamos que el Ministerio de Hacienda y Crédito Público expidió el Decreto 1415 de 2018, por el cual "se modifica parcialmente el Capítulo 2 Título 1 Parte 6 del Libro 1 del Decreto 1625...more

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