International Tax Issues, Withholding Tax, Internal Revenue Code (IRC)

US Senate Finance Committee Makes Changes to Proposed Section 899

Mayer Brown on 6/19/2025

The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier...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

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

Troutman Pepper Locke on 6/11/2025

In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...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

International Tax Withholding | Chapter 3 of the Internal Revenue Code

Freeman Law on 10/19/2022

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Tax Treaties and Exempt Income

Freeman Law on 4/12/2022

Most United States tax treaties provide an exemption for certain categories of employees, including teachers, students, and researchers....more