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Regulatory Agenda › Proposed Legislation › International Tax Issues

Cadwalader, Wickersham & Taft LLP

Is Revenge a Dish Best Served Under the Tax Code?

Cadwalader, Wickersham & Taft LLP on

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

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

Eversheds Sutherland (US) LLP on

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

A&O Shearman

House Ways and Means Committee releases draft tax amendments for 2025 Reconciliation Bill

A&O Shearman on

On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more

Stikeman Elliott LLP

Tax Base Erosion: Canada Responds with Draft EIFEL Rules Legislation

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance released an updated version of the draft legislation that will incorporate the excessive interest and financing expense limitation rules (“EIFEL Rules”) into the Income Tax...more

Stikeman Elliott LLP

Clean Energy Incentives: August 4, 2023 Legislative Proposals Relating to the Income Tax Act and Regulations

Stikeman Elliott LLP on

On August 4, 2023, the Department of Finance of Canada released significant legislative proposals relating to the federal government’s proposed measures to grow Canada’s clean economy. The release includes the draft...more

Proskauer Rose LLP

UK Tax Round Up - July 2021

Proskauer Rose LLP on

In Haworth v HMRC the Supreme Court (SC) upheld the Court of Appeal’s (CA’s) decision to quash a follower notice (FN) and accelerated payment notice (APN) issued to the taxpayer, Mr Haworth. An FN can be issued by HMRC where...more

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