International Tax Issues, Withholding Tax, Foreign Corporations

Proposed Section 899 - The Retaliatory Tax Regime

Kelley Drye & Warren LLP on 6/25/2025

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

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

Paul Hastings LLP on 6/19/2025

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

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

M&A Highlights From ASIC's September Corporate Finance Update

Jones Day on 9/29/2021

ASIC has released its third quarter update on corporate finance regulatory activities. From an M&A perspective, the update includes ASIC's observations on its public M&A deal statistics, outlines ASIC's recent concerns in M&A...more

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

McDermott Will & Schulte on 6/2/2020

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on 1/3/2018

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more