News & Analysis as of

Income Taxes U.S. Treasury

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Trump Accounts: What Employers Need to Know

When Congress passes a bill with a title like the “One Beautiful Bill,” you can already guess who had their fingerprints on it. Out of this legislation comes the so-called Trump Account, a new hybrid savings vehicle that sits...more

McDermott Will & Schulte

IRS announces intent to withdraw controversial DPL rules

The US Department of the Treasury and the Internal Revenue Service (IRS) recently issued Notice 2025-44, announcing their intent to withdraw the controversial disregarded payment loss (DPL) rules finalized at the end of the...more

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

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Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Bowditch & Dewey

U.S. Savings Bonds and Death of the Bondholder

Bowditch & Dewey on

What happens to U.S. Savings Bonds with the death of the bondholder? The answer depends on who owns the savings bond and whether others are also listed as owners or beneficiaries....more

Saul Ewing LLP

New Provision Provides Above-The-Line Deduction for Overtime Pay

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The new tax legislation, part of the "One Big Beautiful Bill", includes a temporary tax break for overtime pay, allowing eligible workers to deduct a portion of their overtime earnings from their federal income taxes. Section...more

Jenner & Block

Client Alert: “Trump Accounts” – Tax-Advantaged Savings Accounts for Children

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On Friday, July 4, President Trump signed into law the One Big Beautiful Bill Act (H.R. 1) (“Big Beautiful Bill”) after narrow approval from both houses of Congress. The legislation extends the Tax Cuts and Jobs Act and...more

Rivkin Radler LLP

Taxes: An American Obsession?

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Last week the United States celebrated the 249th anniversary of its declaration of independence from Great Britain. In celebration of the occasion, President Trump signed into law the One Big Beautiful Act which, among other...more

Procopio, Cory, Hargreaves & Savitch LLP

Elementos clave de la “One Big Beautiful Bill”

La Cámara de Representantes de los EE.UU. aprobó hoy, con una votación de 218 a favor y 214 en contra, la versión previamente autorizada por el Senado del proyecto de ley conocido como “One Big Beautiful Bill”. Se espera que...more

Conn Maciel Carey LLP

The One Big Beautiful Bill’s Overtime and Tax Provisions – Employer Consequences

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As we await the House of Representatives’ vote on the One Big Beautiful Bill, let’s highlight two key provisions that may soon impact employers and employees alike. The Senate bill under consideration before the House of...more

Cooley LLP

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

Cooley LLP on

On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

Hogan Lovells

Update: US retaliatory taxes to be abandoned following G7 agreement on Pillar Two

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The United States has agreed with other G7 members to remove the section 899 protective tax measures from One Big Beautiful Bill in exchange for an agreement to exclude U.S. headed groups from major aspects of the OECD global...more

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

Whiteford on

The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more

DLA Piper

Litigation Funding Tax and Retaliatory Tax: Top Points from the Latest JCT Scores

DLA Piper on

The Joint Committee on Taxation (JCT) on June 22, 2025, released tables providing revenue estimates for provisions of the recent Senate Committee on Finance bill language (JCX-29-25) as well as those of the comparable 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

Paul Hastings LLP

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

Paul Hastings LLP on

On May 22, the U.S. House of Representatives voted to approve the One Big Beautiful Bill (the House Bill), which contained a new addition to the U.S. Internal Revenue Code — Section 899 (House Bill Section 899). On June 16,...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

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

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...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

Fenwick & West LLP

Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations

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The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more

Fox Rothschild LLP

President Names Yet Another Acting IRS Commissioner

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Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more

DLA Piper

REIT Tax News - March 2025

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Welcome to the March 2025 issue of REIT Tax News. Below, we summarize five key developments impacting REITs this past quarter. Carried interest favorable taxation may be in jeopardy - On February 6, 2025, President Donald...more

McDermott Will & Schulte

IRS Roundup February 17 – March 14, 2025

Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more

McDermott Will & Schulte

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

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