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Proposed Legislation › Taxation › Tax Liability

McDonnell Boehnen Hulbert & Berghoff LLP

Death and Taxes Should not be Certainties for the Patent System

McDonnell Boehnen Hulbert & Berghoff LLP on

The Department of Commerce has floated a proposal to tax U.S. patent holdings as a means of reducing the national debt, as outlined in a recent Wall Street Journal article. It is a bad idea that reflects a troubling...more

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

Cadwalader, Wickersham & Taft LLP on

Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

Proskauer - Tax Talks

Senator Tillis Introduced a Bill Taxing Proceeds of Litigation Financing Agreements

Proskauer - Tax Talks on

Senator Thom Tillis introduced a bill (called the “Tackling Predatory Litigation Funding Act”) that would impose additional significant taxes on litigation funding investments. Rep. Kevin Hern (R-OH) introduced a similar bill...more

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill – sports industry sweats the over/under

Eversheds Sutherland (US) LLP on

As the “One Big Beautiful Bill” continues its legislative path through Congress, it remains too close to call on how the final legislation will impact the sports industry. On May 22, 2025, the House of Representatives...more

DLA Piper

House Passes Sweeping Tax Bill: Top Points for the Investment Funds Industry

DLA Piper on

On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...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

Ropes & Gray LLP

Impact of Permanent Establishment Reform for Credit Funds

Ropes & Gray LLP on

On 28 April, the UK Government produced draft legislation for consultation as the latest step in the reform of UK rules on transfer pricing, permanent establishments and diverted profits tax. From an asset management...more

McDermott Will & Emery

Let the Shakedowns Begin: Tax False Claims Legislation in California

McDermott Will & Emery on

Legislators in Sacramento, California, are mulling over one of the most (if not the most) troubling state and local tax bills of the past decade. Senate Bill (SB) 799, introduced earlier this year and recently amended,...more

Jenner & Block

Client Alert: Proposed Changes to Higher Education Financial and Tax Policy: What Colleges and Universities Need to Know

Jenner & Block on

Both Congress and the White House have sought to introduce new financial restrictions for institutions of higher education, building on efforts made during President Trump’s first term. These proposed restrictions include...more

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