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Eversheds Sutherland (US) LLP

Tax Bytes: Week of June 30, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

Cooley LLP

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

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On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

Holland & Knight LLP on

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

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Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

Holland & Knight LLP

Another Surprise in the One Big Beautiful Bill: Excise Tax on Remittances

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As Republicans in the U.S. Senate now consider the reconciliation bill, they will need to consider what tax provisions contained in the One Big Beautiful Bill (OBBB), passed by the U.S. House of Representatives on May 22,...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Consults on Draft Legislation on Transfer Pricing, Permanent Establishments and Diverted Profits Tax

On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more

Hogan Lovells

New Section 899 – Enforcement of remedies against unfair taxes

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On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more

Mayer Brown

Congress Proposes a ‘Big Stick’ to Target Discriminatory Tax Measures

Mayer Brown on

At the onset of its second term, the Trump Administration made clear that the United States opposed the current status of the design and implementation of the Global Anti-Base Erosion Model Rules, (“GloBE” or “Pillar 2”)....more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - September 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Walkers

15% Global Minimum Tax Rate: Draft Legislation lodged in Jersey

Walkers on

Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - February 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Davies Ward Phillips & Vineberg LLP

Government of Canada Releases Package of Proposed Domestic and International Tax Legislation

The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the...more

A&O Shearman

New York proposes sovereign debt restructuring legislation

A&O Shearman on

Legislators in the State of New York (NY), whose law governs many sovereign debt contracts, introduced three general categories of bills related to sovereign debt restructurings. The first is intended to provide support under...more

Barnea Jaffa Lande & Co.

Israeli Privacy Protection Authority Adapts Privacy Protection Laws

Forty years after the enactment of the Israeli Privacy Protection Law, a new draft bill seeks to adapt the Privacy Protection Law to the digital age. One of the main purposes of the draft bill is to preserve the right to...more

Eversheds Sutherland (US) LLP

An incomplete picture: Democratic senators release “framework” for international tax overhaul

On August 25, 2021, Senate Finance Committee members Wyden, Brown, and Warner released draft bill language and a section-by-section summary of their proposed International Tax Reform Framework. The legislative language is...more

Proskauer Rose LLP

UK Tax Round Up - July 2021

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In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more

Eversheds Sutherland (US) LLP

Downsizing from a House to a Manchin: Federal and International tax negotiations continue

As Congress and the White House look to make a deal on infrastructure by this summer, negotiations regarding changes in the tax law continue. Since our prior alert, while progress has been made regarding a bipartisan...more

Holland & Knight LLP

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

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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

Hogan Lovells

Tech Tax – Times Are A Changing?

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It’s been a busy month in the world of tax for tech companies. France and the UK are introducing digital services taxes, and serious work is underway at the OECD that may result in a shake-up of the international tax system...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements - On November 14, 2017, the U.S. Commodity Futures Trading Commission's Division ("CFTC") of Market...more

Carlton Fields

Expect Focus – International, Summer 2015

Carlton Fields on

In This Issue: - TTIP’s Impact on U.S. and EU Trade Relations - Proposed Innovation Box Legislation - Justice Department Recovers Nearly $6 Billion From False Claims Act Cases in 2014 - Rules...more

Carlton Fields

Proposed Innovation Box Legislation

Carlton Fields on

On July 29, the House Ways and Means Committee released draft legislation for a so-called "patent box" proposal, which, if adopted, could mean significant tax savings for many companies engaged in research-intensive...more

Troutman Pepper

Anti-Corruption Law And The Oil And Gas Industry: Evolutions In Both Demand Vigilance

Troutman Pepper on

Businesses in the oil and gas industry are cautioned to pay careful attention to evolutions in anti-corruption law in the jurisdictions where they operate. The U.S. government has successfully enforced the Foreign Corrupt...more

Mintz

Energy And Environment Update -- April 8, 2013

Mintz on

In This Issue: Energy & Climate Debate; Congress; Administration; Department of Energy; Environmental Protection Agency; Department of Interior Department; Department of Commerce; Department of Defense; Department of...more

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