News & Analysis as of

New Legislation Trump Administration International Tax Issues

McDermott Will & Schulte

Corporate taxpayers: Key One Big Beautiful Bill Act changes to international and domestic taxes

On July 4, 2025, US President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law. The legislation introduces significant changes to both international and domestic business tax rules for US taxpayers. While...more

Mayer Brown Free Writings + Perspectives

One Big Beautiful Bill Act Introduces Significant Domestic and International Tax Changes

On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and...more

Alston & Bird

Breaking Down the Tax Provisions of the One Big Beautiful Bill Act

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The One Big Beautiful Bill Act is a massive bill that overhauls much of the U.S. tax system. Our Federal & International Tax and State & Local Tax teams cover the Act’s key tax provisions for individuals and businesses....more

Stinson LLP

One Big Beautiful Bill Explained

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On July 4, President Trump signed into law the One Big Beautiful Bill Act (Bill), which was approved by the Senate and House earlier in the week.  The 870 page-bill covers nearly every sector of the American economy, and...more

Procopio, Cory, Hargreaves & Savitch LLP

Elementos clave de la “One Big Beautiful Bill”

La Cámara de Representantes de los EE.UU. aprobó hoy, con una votación de 218 a favor y 214 en contra, la versión previamente autorizada por el Senado del proyecto de ley conocido como “One Big Beautiful Bill”. Se espera que...more

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

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The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

Herbert Smith Freehills Kramer

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

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

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting Domestic and Multinational Businesses

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill). The House Bill will next be considered by the U.S. Senate, and the administration has set a...more

Ropes & Gray LLP

2025 Tax Legislation Update

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On May 22, 2025, the U.S. House of Representatives passed the “One Big Beautiful Bill Act” (the “BBB”) as part of the Republican Congress’s reconciliation package. The BBB generally extends certain tax provisions of the 2017...more

Eversheds Sutherland (US) LLP

House passes the One Big Beautiful Bill Act with minor revisions to the international tax provisions

On May 22, 2025, the House of Representatives voted along party lines (with one Republican member voting present and two Republican members not voting) to advance the “One Big Beautiful Bill” Act (the OBBB) to the Senate for...more

Troutman Pepper Locke

IRS Withholding Tax Guidance Helpful, But Not Perfect

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As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests. ...more

Carlton Fields

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

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The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Herbert Smith Freehills Kramer

Tax Reform Act Changes to CFC Attribution Rules

The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more

Snell & Wilmer

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

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The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Dickinson Wright

U.S. Tax Reform – What It Means For The Gaming And Hospitality Industry

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Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more

Foodman CPAs & Advisors

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

Foodman CPAs & Advisors

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

Vedder Price on

On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

Ballard Spahr LLP

Analysis of Key Provisions of the Tax Cuts and Jobs Act

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As we are sure you know, H.R. 1, informally known as the Tax Cut and Jobs Act, became law on December 22, 2017. This new law will impact almost all taxpayers. Ballard Spahr's Tax Group has prepared a detailed summary of...more

Fenwick & West LLP

A Concise Summary of the New Tax Law

Fenwick & West LLP on

This summary describes some of the more significant changes made to U.S. federal tax laws by H.R. 1, the bill signed into law by President Trump on December 22, 2017. Except where otherwise noted, the changes take effect in...more

Orrick, Herrington & Sutcliffe LLP

Tax Act Hit to U.S. Taxpayers with Equity Ownership (Even Indirect Minority Ownership) in Foreign Entities with Unremitted...

On December 15, 2017, Congress released its final version of tax reform – the Conference Report Bill (the Bill). The Bill was signed into law by President Trump on December 22, 2017....more

Mayer Brown

President Signs Tax Reform Bill

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On December 22, 2017, the president signed the tax reform bill. It is generally identical to the conference committee bill discussed in our blog post of December 19, and specifically there were no changes with respect to...more

Holland & Knight LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

Impacts on Foreign Operations That Affects Wholly-Owned and Majority Subsidiaries, And Potentially Minority Owned Stakes As Well

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). The Bill was signed into law by President Trump on December 22. ...more

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