News & Analysis as of

Foreign Investment U.S. Treasury

Baker Botts L.L.P.

Navigating the CFIUS Fast Track Program

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In May 2025, the Treasury Department, as chair of the Committee on Foreign Investment in the United States (CFIUS), announced a new “fast track process to facilitate greater investment in U.S. businesses from ally and partner...more

A&O Shearman

Deal structuring in focus as U.S. outbound investment regime takes effect

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Navigating the Committee on Foreign Investment in the United States has long been a key consideration for inbound investors to the U.S. But at the start of 2025, a new regulatory framework was introduced to limit certain...more

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting the Energy and Climate Solutions Sector

On July 4, 2025, President Trump signed H.R. 1, also known as the “One Big Beautiful Bill Act” (OBBB) into law. Initially approved by the U.S. House of Representatives on May 22, 2025, as described in our prior alert here,...more

Akin Gump Strauss Hauer & Feld LLP

Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources (Trump EO Tracker)

Directs the Secretary of the Treasury to issue new guidance within 45 days to enforce the termination of Sections 45Y and 48E tax credits for wind and solar under the One Big Beautiful Bill Act, including restricting safe...more

McDermott Will & Emery

The One Big Beautiful Bill Act: Navigating clean energy tax credits in a new era

On July 4, 2025, US President Donald Trump signed into law a budget reconciliation bill known as H.R.1: the One Big Beautiful Bill Act (OBBBA). The OBBBA generally accelerated phase-outs to the Inflation Reduction Act of 2022...more

Holland & Knight LLP

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

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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

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

Herbert Smith Freehills Kramer

Proposed IRC section 899 ‘revenge tax’ targets residents of certain discriminatory/offending foreign countries

On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May 22, 2025 (the House...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

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

Proskauer - Regulatory & Compliance

Treasury’s Latest Moves: Fast-Track for Foreign Investors & Outbound AI Investment Inquiry

The U.S. Department of the Treasury (“Treasury”) has been active in the context of the Committee on Foreign Investment in the United States’ (“CFIUS”) and the Outbound Investment Security Program (“OISP”). The main updates...more

Paul Hastings LLP

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

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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

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

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Executive Summary - 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,...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

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

Baker Donelson

CFIUS Announces Fast Track Pilot Program: How Foreign Investors Can Take Advantage

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The Department of Treasury announced a forthcoming Fast Track Pilot Program where foreign investors can register to streamline compliance with the Committee on Foreign Investment in the United States (CFIUS). The goal of the...more

Torres Trade Law, PLLC

Outbound enforcement has started; Treasury contacting U.S. investors

Even though the Trump administration is reviewing the outbound foreign investment review regime, enforcement has begun. We’ve now heard multiple reports that the Treasury Department is reaching out to U.S. venture capital and...more

McDermott Will & Emery

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

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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

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting the Energy and Climate Solutions Sector

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill).1 The House Bill will next be considered by the U.S. Senate, and the administration has set a...more

Wilson Sonsini Goodrich & Rosati

The CFIUS “Fast-Track” Pilot Program: Why You (Probably) Can Ignore This Space

On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced that it will create a “fast-track pilot program” for certain foreign investors. The stated goal of the program is to streamline investment reviews by...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

Fox Rothschild LLP

US Treasury Department Has Begun Enforcing New Outbound Investment Rules

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The U.S. Department of the Treasury has started enforcing final regulations that restrict, and in some cases prohibit, U.S. companies, funds and individuals from making certain investments in some technology industries owned...more

Troutman Pepper Locke

New “Fast-Track” Announced for Foreign Investment Approval

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On May 8, the Treasury Department announced a plan to introduce a new Known Investor portal as a key component of the “fast-track” process for investments by U.S. allies and partners under review by the Committee on Foreign...more

Akin Gump Strauss Hauer & Feld LLP

CFIUS Announces Fast Track Pilot Program for Certain Investors

On May 8, 2025, the U.S. Department of the Treasury (Treasury) announced plans to establish a “fast-track” review process for the Committee on Foreign Investment in the United States (CFIUS). This initiative implements a key...more

Venable LLP

Piloting a "Fast Track" at CFIUS: New Process for Foreign Investors Expected Soon

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On May 8, 2025, the U.S. Department of the Treasury, which leads the interagency Committee on Foreign Investment in the United States (CFIUS), announced plans to establish a fast-track process for foreign investors, including...more

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