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Foreign Investment Tax Reform

Mayer Brown

Asia Tax Bulletin - Summer 2025

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We present to you the Summer 2025 edition of the Asia Tax Bulletin. It contains tax developments in Asia on a host of topics, such as Hong Kong’s and Japan’s tax legislation to implement the Minimum Global Tax (also referred...more

Vinson & Elkins LLP

Update: OBBBA Tax Provisions Impacting REITs and Foreign Investors

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On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful...more

White & Case LLP

Amendments to IRA Tax Credits in Congressional Budget Bill

White & Case LLP on

Update: The House of Representatives passed (by a vote of 218-214) the budget reconciliation bill (H.R. 1, the "One Big Beautiful Bill Act") on July 3, 2025. The bill now goes to the President for signature....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

Cadwalader, Wickersham & Taft LLP

Is Revenge a Dish Best Served Under the Tax Code?

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as...more

K&L Gates LLP

How President Trump's "One Big Beautiful Bill" Will Impact Businesses in Australia

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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, including US...more

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

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

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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

King & Spalding

“Revenge Tax”

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Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

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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

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

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

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Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

White & Case LLP

Amendments to IRA Tax Credits in the House Budget Bill

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On May 22, 2025, the House of Representatives passed (by a vote of 215-214-1) its version of the budget reconciliation bill (H.R. 1, the "One Big Beautiful Bill Act") containing numerous tax reform provisions. Below are our...more

White & Case LLP

Amendments to IRA Tax Credits in the House Ways and Means Budget Bill

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On May 14, 2025, the House Committee on Ways and Means advanced its budget reconciliation bill containing numerous tax reform provisions. Below are our summaries of the proposed amendments to certain tax credits under the...more

Morgan Lewis

Investment Opportunities and Regulatory Framework in Kazakhstan

Morgan Lewis on

The Republic of Kazakhstan, having vast reserves of natural resources and being located at the intersection of Europe and Asia, competes for investments in the region. As such, and as laid out in this article, the government...more

Allen Barron, Inc.

Create a New Trust or Update an Existing Estate Plan

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If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...more

K&L Gates LLP

Australian Federal Budget 2025-2026–Key Tax Measures and Instant Insights

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The Australian Federal Government has just released its budget for 2025-26. The K&L Gates tax team outlines the key announced tax measures and our instant insights into what they mean for you in practice....more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

McDermott Will & Emery

Navigating the UTPR and ISDS: Implications in the EU

The global tax landscape is experiencing a profound transformation as the OECD/G20’s Pillar Two rules are adopted. Among these, the Undertaxed Profits Rule (UTPR) has emerged as a pivotal mechanism designed to ensure that...more

A&O Shearman

How will the Trump administration impact M&A?

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M&A practitioners anticipate a ‘Trump bump’ - The scale of Donald Trump’s victory in the presidential election – and the fact the Republicans now have full control of Congress – has been greeted with optimism by U.S....more

Akin Gump Strauss Hauer & Feld LLP

US Presidential Elections 2024—What is at Stake for Swiss Companies and Investors?

The November U.S. Presidential electoral campaign is in full swing. Since President Joe Biden ended his reelection bid and Vice President Kamala Harris secured the Democratic Party nomination, polls now show a tight race...more

Jones Day

Chile’s New Mining Royalty Law: What It Means for Foreign Investors

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Since the 1990s, Latin American states have sought to attract large-scale foreign investment by implementing specific policies and regulatory regimes aimed at attracting investors from abroad. This trend has, however,...more

White & Case LLP

The future of US-Latin America trade relations: What can we achieve in the next few years?

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While the Washington Consensus policies resulted in seven years of economic growth in the 1990s, the years that followed brought about a period of recession and stagnation - 71% US trade with Latin America is dominated...more

A&O Shearman

The Book Minimum Tax, Pillar 2 and Creditable Foreign Income Taxes

A&O Shearman on

As discussed in our alert earlier this week, the recently announced proposed reconciliation package—the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”)—would impose a new 15% minimum tax on the adjusted financial...more

Bennett Jones LLP

Canada Introduces "Excessive Interest and Financing Expenses Limitation"

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Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more

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