News & Analysis as of

Loans Withholding Tax

Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

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

King & Spalding

“Revenge Tax”

King & Spalding on

Withholding Tax Rules Under Current Law - Current US tax law provides for a 30% withholding tax on interest paid by a US borrower to foreign lenders. However, many foreign lenders are exempt from this tax, either under the...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Troutman Pepper Locke

The Big Beautiful Bill and the Effects on Bank Lending Into the US

Troutman Pepper Locke on

Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more

White & Case LLP

European Real Estate Finance: Recent developments - December 2019

White & Case LLP on

As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

White & Case LLP

European Real Estate Finance: Recent developments – June 2019

White & Case LLP on

As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more

White & Case LLP

New Tax Rates Applicable to Bond and Sukuk Income, Tier II loans and securitizations

White & Case LLP on

Withholding tax rates on income derived from Eurobonds and lease certificates issued outside of Turkey, on interest payments of Tier II loans and securitization financings; as well as BITT applicable to securitizations backed...more

Hogan Lovells

Draft tax legislation for 2017 released

Hogan Lovells on

Following the 2017 Budget presented before Parliament on 22 February 2017, the draft tax legislation for the specific tax proposals was released on 19 July 2017 for comment. Comments should be made by 18 August 2017. ...more

Morgan Lewis

Tax Measures in the UK 2015 Summer Budget

Morgan Lewis on

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

Katten Muchin Rosenman LLP

LSTA Publishes Revised Documents Effective April 24, 2014

The Loan Syndications and Trading Association (LSTA) has released new forms of its primary trading documents, effective for trades entered into on or after April 24, 2014. The LSTA's updated forms are primarily...more

Saul Ewing Arnstein & Lehr LLP

U.S. District Court Decision Court Treats Physician Loans as W-2 Income Rather Than Bona Fide Debt

A recent federal court decision illustrates how “loan” arrangements between physicians and their employers, if not properly structured, may be treated as the payment of taxable compensation and the employers may be hit with...more

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