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Proposed Legislation Internal Revenue Code (IRC) U.S. Treasury

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

Paul Hastings LLP

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

Paul Hastings LLP on

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

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...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

Jenner & Block

Client Alert: Non-Profits Targeted Under New Tax Code Proposals

Jenner & Block on

House Bill 9495 (H.R. 9495), a bill passed during the 118th Congress, is legislation worth watching for non-profits and other aid organizations. H.R. 9495 passed the House on November 21, 2024, and if passed during the new...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Proposed Regulations on the Advanced Manufacturing Production Credit under Section 45X of the...

The proposed regulations provide important clarity on the distinction between substantial and superficial modification for purposes of determining eligible components produced by the taxpayer, along with guidance as to...more

Morrison & Foerster LLP

Proposed “Inflation Reduction Act” Could Significantly Curtail Carried Interest Tax Benefits

On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more

Fenwick & West LLP

Senate Passes Infrastructure Bill Including Language on Digital Assets and Reporting of Crypto Transactions

Fenwick & West LLP on

On August 10, 2021, the U.S. Senate passed an infrastructure bill containing explicit rules to be inserted into the Internal Revenue Code regarding digital assets. The passage marks the first time that language on this topic...more

Holland & Knight LLP

Biden Administration's FY 2022 Budget and Its Tax Increases for Corporations, Wealthy

Holland & Knight LLP on

By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more

Eversheds Sutherland (US) LLP

Expensing 2.0 – Treasury and the Internal Revenue Service thoughtfully consider comments on the proposed § 168(k) regulations and...

On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more

Brownstein Hyatt Farber Schreck

Treasury Releases Guidance on Permissibility of State Legislation to Circumvent SALT Deduction Cap

On Aug. 23, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under Section 170 of the Internal Revenue Code (Code) addressing the federal income tax treatment...more

Foley & Lardner LLP

Tax Reform and Tax-Exempt Bonds: Risks Presented by the Tax Cuts and Jobs Act

Foley & Lardner LLP on

On November 2, 2017, the “Tax Cuts and Jobs Act” was introduced in the House of Representatives. This act has immediate and far-reaching implications for tax-exempt finance. Among other things, the Tax Cuts and Jobs Act...more

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