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Foreign Investment Taxation

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

Cadwalader, Wickersham & Taft LLP

Quarter End Fireworks, June 2025 - In the News: (Potentially) Taking Revenge Through Tax

As we power through what remains of this quarter, working to get deals closed before quarter end next week, you may have noticed some additional (and new!) blacklining in the tax section of your credit agreement thanks to a...more

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

Holland & Knight LLP on

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Morgan Lewis

Key Considerations for Restructuring Investment in China

Morgan Lewis on

Geopolitical tensions have increasingly impacted business operations in China, prompting multinational companies to adopt contingency strategies, including spin-offs or restructuring. These efforts present both challenges and...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

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...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

IR Global

Key Changes to the DRC Mining Code: A New Era for Investors and National Development

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The Democratic Republic of Congo (DRC), home to some of the world’s richest deposits of cobalt, copper, and other critical minerals, enacted major revisions to its Mining Code in March 2018. These reforms marked a significant...more

McDermott Will & Emery

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

McDermott Will & Emery 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

Morgan Lewis

Taxation of Dividends Received by Non-Residents in Kazakhstan Starting 2026

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Kazakhstan will soon adopt a new tax code, with the bill currently in Parliament. It is expected that the new tax code will be adopted this year and come into force beginning 2026. This LawFlash summarizes the general...more

Farrell Fritz, P.C.

Sales of Real Estate Involving Non-U.S. Sellers – FIRPTA Considerations for Both Parties

Farrell Fritz, P.C. on

Transactions involving the disposition of a U.S. real property interest (“USRPI”) by a foreign person (i.e., a nonresident alien individual or foreign entity, the seller) are subject to the Foreign Investment in Real Property...more

IR Global

Cross-border mobility in Portugal

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What are the key considerations for businesses and individuals navigating cross-border mobility in your jurisdiction? Navigating cross-border mobility in Portugal involves several key considerations for businesses and...more

Wilson Sonsini Goodrich & Rosati

The Non-U.S. Start-Up’s Guide to Navigating the U.S. Tax Implications of U.S. VC Investment

U.S. start-up investors are increasingly looking overseas for investment opportunities. As U.S. investment in UK and other non-U.S. start-ups rises, founders of those start-ups should be aware of the potential impact of the...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

White & Case LLP

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

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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

J.S. Held

Ending the Draught: Africa’s Return to International Debt Markets

J.S. Held on

On 12 February, the Kenyan government added momentum to Africa’s return to international debt markets by successfully issuing a USD 1.5 billion Eurobond. The issuance followed similar moves by Côte d’Ivoire and Benin which...more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

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Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

McDermott Will & Emery

Cross-Border M&A Comparison Table

McDermott Will & Emery on

Cross-border deals are complex and require mastery of multiple disciplines with unique considerations in different regions. Review our table comparing cross-border deal considerations for various topics across the United...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Would Affect the Taxation of US Real Estate for Foreign Investors

On December 28, 2022, the Treasury Department released a set of proposed regulations that, if finalized, would alter key rules affecting many real estate funds, sovereign wealth funds and other foreign investors in U.S. real...more

Morgan Lewis

The Next Big Things: Insights for 2020

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Autonomous cars, sports betting, and CBD products have burst onto the scene, setting the stage for major developments in how companies do business and how regulators monitor new innovations....more

Hogan Lovells

What dealmakers need to know about the UK election result and its impact on UK investing in 2020

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The result of the UK’s third general election in less than five years marks a significant shift in the political landscape in the world’s 5th biggest economy. After nearly a decade marked by political stalemate, the...more

Hogan Lovells

Non-resident SDLT surcharge: adding 1% and more complexity

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When the government announced in 2018 that foreign investors into the UK property market were to be targeted with an additional SDLT levy, we said that the devil would be in the detail....more

Hogan Lovells

Dancing To The Wrong Tune? Theresa May’s Additional SDLT Levy On Foreign Buyers

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Theresa May’s announcement at the Conservative Party conference that foreign investors into the UK property market were going to be targeted with an additional SDLT levy has caused further consternation within the industry....more

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