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Vinson & Elkins LLP

Update: OBBBA Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful...more

Herbert Smith Freehills Kramer

Proposed IRC section 899 ‘revenge tax’ targets residents of certain discriminatory/offending foreign countries

Herbert Smith Freehills Kramer on

On June 16, 2025, the Senate Finance Committee released its proposed version of the “One Big Beautiful Bill Act” (the Senate Bill). The House of Representatives passed its version of the bill on May 22, 2025 (the House...more

Seward & Kissel LLP

Should you call 911 about Section 899?

Seward & Kissel LLP on

On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Orrick, Herrington & Sutcliffe LLP

UK Founder Series: Flip Back from the U.S. – Key U.S. Tax Considerations

Orrick, Herrington & Sutcliffe LLP on

Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Holland & Knight LLP

Proposed Treasury Regulations Reverse Guidance on Domestically Controlled REITs

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more

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