International Tax Issues, Tax Liability, Proposed Legislation

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on 6/19/2025

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

“Revenge Tax”

King & Spalding on 6/13/2025

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

The Big Beautiful Bill and the Effects on Bank Lending Into the US

Troutman Pepper Locke on 6/2/2025

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

Summary of key provisions in House reconciliation bill

A&O Shearman on 5/29/2025

On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Mintz - Tax Viewpoints on 5/20/2025

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

McDermott Will & Schulte on 10/21/2021

Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more