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Mintz - Tax Viewpoints

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

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

Seward & Kissel LLP

Section 883 Tax Exemption for Cargo Shipping and Cruise Lines At Risk?

Seward & Kissel LLP on

Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more

Cadwalader, Wickersham & Taft LLP

Hargreaves Property : What Does the Latest Decision Mean for UK Withholding Tax?

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In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to UK...more

Cadwalader, Wickersham & Taft LLP

UK Government Considers Changes to the Rules on Sovereign Immunity from Direct Taxation

Cadwalader, Wickersham & Taft LLP on

The UK Government has recently consulted on a revised approach to sovereign immunity from direct taxation. The consultation was brought about owing to the view that whilst the scope of sovereign immunity-based exemptions has...more

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