News & Analysis as of

Senate Finance Committee Income Taxes Foreign Tax

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

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

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

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