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Internal Revenue Service Foreign Investment U.S. Treasury

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 17, 2025

Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more

A&O Shearman

Notice 2024-10 Provides Interim Guidance on the Application of the CAMT with Respect to Controlled Foreign Corporations and...

A&O Shearman on

On December 15, 2023, the U.S. Treasury Department (“Treasury”) and the U.S. Internal Revenue Service (“IRS”) issued Notice 2024-10 (the “Notice”), providing much needed interim guidance on the application of the Corporate...more

Vinson & Elkins LLP

New Regulations Impact Tax Considerations for Foreign Investment in Real Estate

Vinson & Elkins LLP on

Key Takeaways- While foreign investors are typically taxed on gain from the sale of U.S. real property interests (which include interests in most equity REITs), they are generally exempt from tax on gain from the sale of...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

A&O Shearman

The Book Minimum Tax, Pillar 2 and Creditable Foreign Income Taxes

A&O Shearman on

As discussed in our alert earlier this week, the recently announced proposed reconciliation package—the Inflation Reduction Act of 2022, H.R. 5376 (the “Bill”)—would impose a new 15% minimum tax on the adjusted financial...more

Dorsey & Whitney LLP

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

Dorsey & Whitney LLP on

An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

McDermott Will & Emery on

The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

Cadwalader, Wickersham & Taft LLP

Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives

I. Introduction - On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed...more

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