News & Analysis as of

Foreign Investment Investors Income Taxes

Davies Ward Phillips & Vineberg LLP

Retaliatory Taxes: Pending Legislation in U.S. Congress May Adversely Impact Returns on Inbound Investment

As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more

Seward & Kissel LLP

Should you call 911 about Section 899?

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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

Sheppard Mullin Richter & Hampton LLP

U.S. Budget Bill Targets Foreign Companies with New Tax Hikes: What French Businesses Need to Know

The One Big Beautiful Bill Act (OBBBA) was passed by the U.S. House of Representatives on May 22, 2025 by a narrow vote of 215-214. OBBBA includes a new U.S. tax provision that could significantly increase taxes on foreign...more

Allen Barron, Inc.

The Potential Tax Impact of Foreign Investments

Allen Barron, Inc. on

A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more

IR Global

Planning for the uncertain - The Visionaries

IR Global on

Q1 How should businesses and individuals prepare for and respond to new governments across the world? Governments play a pivotal role in shaping the financial landscape by imposing regulations, setting corporate and...more

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

Strafford on

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

K&L Gates LLP

Doing Business in Australia

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Australia welcomes new business and foreign investment by providing a strong economy, a stable political environment and a skilled and talented workforce. Our comprehensive guide to Doing Business in Australia has been...more

International Lawyers Network

Establishing a Business Entity in the United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more

International Lawyers Network

Establishing A Business Entity In The United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...more

International Lawyers Network

Establishing A Business Entity In Italy (Updated)

1. Types of Business Entities - 1.1 Premises - The Italian law provides multiple forms of organizational structures in order to do business in Italy, which differ from one another due to the extent of the liability...more

Cooley LLP

Blog: Primer - U.S. Tax Considerations for Venture Capital Funds

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We are frequently asked by our fund manager clients about what tax issues they should consider when forming a new venture capital fund or investing in portfolio companies. In this post, we outline a few key considerations for...more

Tonkon Torp LLP

The Alphabet Soup Of Working With Foreign Real Estate Investors

Tonkon Torp LLP on

Given the continuous fluctuation in business immigration, tariffs, and international relations, it shouldn’t be a surprise that foreign investment into the U.S. (especially by China), has slowed. And yet, it is still...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

McDermott Will & Schulte

New Regulations on Withholding Income Tax for Overseas Investors in China

To promote the growth of foreign investment, the “Notice on Policies concerning Temporarily Not Levying Withholding Tax on Distributed Profit used for Direct Investment by Overseas Investors” was jointly issued on December...more

Mintz

Proposed U.S. Tax Reform May Impact Investments in U.S. Real Estate

Mintz on

Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more

Mintz

TechConnect - Your Law Firm Link to Industry News - September 2017

Mintz on

Letter from the Editors - Words are very powerful and the language we use often frames a discussion. For example, the term “shareholder activist” sounds like a consumer friendly person who has everyone’s best interests at...more

Cole Schotz

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

Cole Schotz on

The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more

Bilzin Sumberg

Tax Planning for Chinese Investment in U.S. Real Estate

Bilzin Sumberg on

According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors...more

Sheppard Mullin Richter & Hampton LLP

2014—A big year for Circular 698?

This year will mark a half-decade since the release of Circular 698. The confluence of local enforcement and increased exits by off-shore investors may make 2014 its most interesting year....more

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