News & Analysis as of

Foreign Investment Tax Reform Tax Liability

Vinson & Elkins LLP

Update: OBBBA Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

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

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

King & Spalding

“Revenge Tax”

King & Spalding on

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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Jones Day

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

Jones Day on

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

Proskauer - Tax Talks

Tax Reform – I.R.S. Updates Withholding Tax Guidance on Sales of Partnership Interests

Proskauer - Tax Talks on

On April 2, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-29 (the “Notice”), announcing the intention of the IRS and the Department of the Treasury to issue regulations regarding the withholding requirements...more

Troutman Pepper Locke

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

Troutman Pepper Locke on

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

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