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Proposed Legislation U.S. Treasury

Jenner & Block

Client Alert: “Trump Accounts” – Tax-Advantaged Savings Accounts for Children

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On Friday, July 4, President Trump signed into law the One Big Beautiful Bill Act (H.R. 1) (“Big Beautiful Bill”) after narrow approval from both houses of Congress. The legislation extends the Tax Cuts and Jobs Act and...more

Paul Hastings LLP

What the GENIUS Act Means for UK and Foreign Stablecoin Issuers

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Stablecoins are commanding increasing attention from global regulators. While the U.K. is moving steadily toward a clearer regulatory framework, the U.S. is advancing federal legislation that could reshape how foreign...more

Conn Maciel Carey LLP

The One Big Beautiful Bill’s Overtime and Tax Provisions – Employer Consequences

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As we await the House of Representatives’ vote on the One Big Beautiful Bill, let’s highlight two key provisions that may soon impact employers and employees alike. The Senate bill under consideration before the House of...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025 #2

The Senate Republicans continue to meet internally and with stakeholders regarding the provisions of a reconciliation package (H.R. 1). Senate Majority Leader John Thune (R-SD) made it clear that the Senate will make...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, June 2025

House Passes Reconciliation Package, with Senate Expected to Make Changes: On May 22, the House of Representatives passed H.R. 1, “The One, Big, Beautiful Bill Act,” legislation authorized under the FY 2025 concurrent budget...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 67: Stablecoins: The GENIUS Act Explained

FS Vector’s Jackson Mueller sits down with RegFi co-hosts Jerry Buckley and Sasha Leonhardt to discuss the recently Senate-passed GENIUS Act. They explore the regulatory requirements that would be established under the...more

Seyfarth Shaw LLP

A New Chapter for Opportunity Zones

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The Opportunity Zone program (the “OZ Incentive Program”), launched under the 2017 Tax Cuts and Jobs Act, was designed to spur economic development in distressed communities by offering tax incentives to investors. As part of...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

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

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The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more

Holland & Knight LLP

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

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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

Senate Updates Code Section 899

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On Monday, 16 June 2025, the Senate Finance Committee released its version (the Senate Proposal) of the Section 899 retaliatory tax provisions that also are included in the “One Big Beautiful Bill Act” (the Act) that was...more

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

Wilson Sonsini Goodrich & Rosati

Navigating the Future of Stablecoins: Highlights from the Proposed GENIUS Act

On June 17, 2025, the U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. If enacted, the bill would establish a comprehensive federal regulatory framework for stablecoins...more

DLA Piper

Litigation Funding Tax and Retaliatory Tax: Top Points from the Latest JCT Scores

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The Joint Committee on Taxation (JCT) on June 22, 2025, released tables providing revenue estimates for provisions of the recent Senate Committee on Finance bill language (JCX-29-25) as well as those of the comparable 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

Cozen O'Connor

Stablecoins: Navigating the Money Transmitter Minefield & Forthcoming Federal Regulatory Frameworks

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As digital assets gain traction across financial markets, stablecoins—cryptocurrencies pegged to fiat currencies like the U.S. dollar—are emerging as a practical medium for capital contributions, settlements, and liquidity...more

Pillsbury Winthrop Shaw Pittman LLP

Status Update: Renewable Energy Tax Credits Under the Big Beautiful Bill

Most tax credits would be subject to early termination dates and phase-outs. The House bill would end the ability to sell tax credits for cash, but the Senate Finance Committee proposal would restore transferability. New...more

Katten Muchin Rosenman LLP

Senate Passes GENIUS Act: Landmark Federal Stablecoin Bill Advances to House

The US Senate has passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) by a vote of 68-30, a significant development for cryptocurrency regulation in the United States. This passage...more

Paul Hastings LLP

GENIUS Act Clears Senate, SEC Withdraws Proposed Rules and Bitcoin Reserve Bill Introduced

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The Senate passed the GENIUS Act with bipartisan support, marking a significant step forward in advancing stablecoin legislation. Legislative action on stablecoins will now move to the House of Representatives. The House...more

Davies Ward Phillips & Vineberg LLP

Retaliatory Taxes: Pending Legislation in U.S. Congress May Adversely Impact Returns on Inbound Investment

As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more

Jones Day

Senate Passes GENIUS Act, Clearing Hurdle for Federal Stablecoin Framework

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The vote marks the first time the U.S. Senate has passed significant digital asset legislation and puts the industry one step closer to regulatory clarity for certain stablecoins....more

Paul Hastings LLP

Update: Senate Finance Committee Releases Its Version of Section 899 of the One Big Beautiful Bill

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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

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

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On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...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

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