News & Analysis as of

Internal Revenue Code (IRC) International Tax Issues U.S. Treasury

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

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

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

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

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting Domestic and Multinational Businesses

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). The House Bill will next be considered by the U.S. Senate, and the administration has set a...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

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Eversheds Sutherland (US) LLP

On notice: IRS and Treasury preview guidance related to Pillar Two taxes and extend foreign tax credit relief

The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more

McDermott Will & Schulte

Proposed New Code Sec. 163(n) and Removal of Expense Allocation to GILTI

This column describes new proposed Code Sec. 163(n) and the proposed general removal of expense allocation to GILTI in the Build Back Better Act (the “BBBA”). This column focuses on the version of the BBBA proposed on...more

A&O Shearman

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

McDermott Will & Schulte

Proposed Regulations under Sections 863(b) and 865(e)(2) Revise the Rules for Sourcing Income

Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more

Eversheds Sutherland (US) LLP

Much ado about nothing - IRS provides advance payments guidance with release of Notice 2018-35

On April 12, 2018, the Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-35 (Notice) that provides transitional guidance relating to advance payments under Rev. Proc. 2004-34. Despite the...more

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