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
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