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International Tax Issues Foreign Investment Withholding Tax

Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

The One Big Beautiful Bill Act (the ​“Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...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

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

Freeman Law

International Tax Treaty: China

Freeman Law on

Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Freeman Law

International Tax Treaty: Australia

Freeman Law on

Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

Bennett Jones LLP

Bennett Jones Speaks before Senate Committee on Tax Issues for Energy Investments

Bennett Jones LLP on

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...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

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