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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

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

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

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

Seward & Kissel LLP

Should you call 911 about Section 899?

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On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more

Venable LLP

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

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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

McDermott Will & Emery

The Proposed US Tax Regime for Non-US Investors and Companies

McDermott Will & Emery on

On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions Impacting the Energy and Climate Solutions Sector

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill).1 The House Bill will next be considered by the U.S. Senate, and the administration has set a...more

White & Case LLP

Amendments to IRA Tax Credits in the House Budget Bill

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On May 22, 2025, the House of Representatives passed (by a vote of 215-214-1) its version of the budget reconciliation bill (H.R. 1, the "One Big Beautiful Bill Act") containing numerous tax reform provisions. Below are our...more

White & Case LLP

Amendments to IRA Tax Credits in the House Ways and Means Budget Bill

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On May 14, 2025, the House Committee on Ways and Means advanced its budget reconciliation bill containing numerous tax reform provisions. Below are our summaries of the proposed amendments to certain tax credits under the...more

Dorsey & Whitney LLP

U.S. National Security Issues in Cross-Border Food, Beverage & Agribusiness Deals

Dorsey & Whitney LLP on

On October 28, 2021, a bipartisan group of U.S. Senators introduced the Food Security is National Security Act of 2021 (the “Act”). Among other things, the Act would require the Committee on Foreign Investment in the United...more

Dorsey & Whitney LLP

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

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An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration: 2017 Recap and 2018 Outlook

On January 20, 2017, businessman Donald J. Trump was sworn in as the 45th President of the United States following a contentious and unconventional 2016 presidential election. Republicans also successfully maintained control...more

Akin Gump Strauss Hauer & Feld LLP

What’s New in Washington - November 2017

Congress continues its heavy workload with the Thanksgiving recess roughly three weeks away. On October 26, the House passed the Senate’s Fiscal Year 2018 budget resolution by the slim margin of 216-212—opening the door for...more

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