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Proposed Legislation › Tax Liability › Withholding Tax

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

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

Mintz - Tax Viewpoints

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Mintz - Tax Viewpoints on

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

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