News & Analysis as of

Proposed Legislation Trump Administration International Tax Issues

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

Cadwalader, Wickersham & Taft LLP

Is Revenge a Dish Best Served Under the Tax Code?

Among the myriad provisions of the budget bill that passed the U.S. House of Representatives last month, one that has recently gained increased prominence in recent weeks is proposed Section 899, increasingly referred to as...more

Cadwalader, Wickersham & Taft LLP

Senate and House Seek Common Ground on Tax Bills

On June 16, 2025, the Senate Finance Committee released its draft FY 2025 budget bill, which generally incorporates most of the House’s tax proposals, which we previously summarized here, but also differs in various aspects. ...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

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

Venable LLP on

As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...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

Eversheds Sutherland (US) LLP

House passes the One Big Beautiful Bill Act with minor revisions to the international tax provisions

On May 22, 2025, the House of Representatives voted along party lines (with one Republican member voting present and two Republican members not voting) to advance the “One Big Beautiful Bill” Act (the OBBB) to the Senate for...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

Lowndes

Tax Bill Passes in Congress, Off to President Trump for Signature

Lowndes on

Congress has passed the Tax Cuts and Jobs Act, and President Trump is expected to sign it almost immediately. ...more

Orrick, Herrington & Sutcliffe LLP

How Tax Reform Could Trigger Significant Taxes For Unwary Stockholders (And Funds) In Foreign Companies

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). - Statutory language of the Bill may cause an unexpected tax hit on unwary U.S. stockholders who...more

Lowndes

BREAKING: House Passes Final $1.5T Tax Cut Bill

Lowndes on

This morning, Congress passed the Republican’s tax reform bill, the Tax Cuts and Jobs Act (the “Act”). President Trump is expected to sign the Act into law almost immediately. The Act will drastically change the Internal...more

Butler Snow LLP

Tax Law Changes Under The Tax Cuts And Job Act

Butler Snow LLP on

On December 15th, the congressional conference committee charged with reaching a consensus on the competing versions of the Senate and House tax reform bills released its conference report containing the language of the final...more

Bradley Arant Boult Cummings LLP

High-Level Summary of Conference Committee Version of the “Tax Cuts and Jobs Act” as Filed

Details of a final agreement among House and Senate Republicans emerged last week -- including rate cuts for “C” corporations, individuals and pass-through businesses. Here’s a summary of what the conferees have agreed to,...more

Cadwalader, Wickersham & Taft LLP

Seventeen Provisions to Watch in the Senate Tax Reform Bill

On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more

Hogan Lovells

U.S. Tax Reform in Final Stretch

Hogan Lovells on

This past week, on 1 December, the Senate voted 51-49 to advance its version of U.S. tax reform legislation. This sets the stage for a conference committee process to occur over the next two weeks, in which the Senate and...more

Ballard Spahr LLP

Federal Tax Reform: An Analysis of the House and Senate Bills

Ballard Spahr LLP on

As we are sure you know, both the U.S. House of Representatives and Senate have passed their own versions of tax legislation, known as the Tax Cuts and Jobs Act. The two different bills will be reconciled in a conference...more

Ballard Spahr LLP

Federal Tax Reform: Side-by-Side Comparison of the Senate and House Approved Bills, Plus the Big Picture

Ballard Spahr LLP on

Last updated December 5 - The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill,...more

Ballard Spahr LLP

Federal Tax Reform: The Current State of Play & The Big Picture (Updated 12/5)

Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

Polsinelli

Tax Cuts and Jobs Act Update: Senate Approval Moves Bill Forward

Polsinelli on

The Senate passed a version of the Tax Cuts and Jobs Act that differs significantly from the House-passed bill but still contains several similar proposals that lower individual and business tax rates, completely revamp the...more

Herbert Smith Freehills Kramer

Tax Reform Bills Seek Largest Restructuring of Tax Code in More Than a Generation

On Nov. 16, 2017, the House of Representatives passed its version of the tax reform bill, the Tax Cuts and Jobs Act. The Senate Budget Committee voted on Nov. 28, 2017, to send the Senate version of the bill to the floor,...more

A&O Shearman

House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

A&O Shearman on

On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

Cadwalader, Wickersham & Taft LLP

Fifteen Provisions to Watch in the Tax Reform Proposals

On November 14, 2017, Senate Finance Committee Chairman, Orrin Hatch (R-Utah), released his modified tax reform plan (“Senate Bill”), which adopts some of the House Bill proposals (as amended) (“House Bill”), but also...more

Ballard Spahr LLP

Federal Tax Reform: How the Newly Passed House Bill Compares to the Senate Bill – A Side-by-Side Comparison, Plus the Big Picture

Ballard Spahr LLP on

Last updated 11/17/2017 The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and...more

Sheppard Mullin Richter & Hampton LLP

U.S. Tax Reform: The Current State of Play

Yesterday the House of Representatives voted on and passed the Tax Cuts and Jobs Act. If passed by the Senate, the Act would significantly change the current federal income tax regime in the United States. ...more

Ballard Spahr LLP

Federal Tax Reform: The Senate Bill – Comparison to the House Bill, and Evaluating the Bigger Picture

Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

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