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Proposed Legislation Organization for Economic Co-operation and Development International Tax Issues

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

Cooley LLP on

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

K&L Gates LLP on

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

Holland & Knight LLP on

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

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

Proskauer Rose LLP on

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

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

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