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
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
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
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
“Famously the author of “The Art of the Deal,” President Donald Trump considers himself more of a dealmaker than an ideologue. He sees the world as zero sum and aims to gain maximum leverage. As a result, he’s not as wedded...more
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
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
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
On May 22, 2025 the House of Representatives passed its version of the “One Big Beautiful Bill Act” (the “BBB”). As described in our prior Alert, the proposed package includes several key provisions of particular importance...more
Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more
On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more
One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more
Debt Limit Negotiations Stall as Treasury Department Begins Extraordinary Measures. On Jan. 19, the U.S. government reached its $31.4 trillion borrowing limit, which was signed into law by President Joe Biden late last year....more
Congress- U.S. Senate- Committee on Banking, Housing, and Urban Affairs- Brown Presses FSOC to Protect Consumer Data-...more
Bajo el concepto de “FATCA recíproca”, las instituciones financieras y los corredores deben comenzar a prepararse para asumir mayores y más amplias responsabilidades de reportaje. Como partes interesadas de FATCA, las...more
Early on December 11, 2021, the Senate Finance Committee released its version of the Build Back Better Act (the “Act”). While the Senate Finance Committee version of the Act largely replicates the clean energy proposals...more
It has been more than eight months since the enactment of the CARES Act, yet here we are, with the end of 2020 in sight, and we are still debating whether taxpayers should be allowed to claim a deduction for business expenses...more
Tax Tidbit - Regulators have until June 22 to finalize guidance on the Tax Cuts and Jobs Act (P.L.115-97). The 18-month mark since the legislation was signed into law is quickly approaching. The Treasury Department and...more
TAX TIDBIT - SPOILER ALERT: The following piece contains Game of Thrones and Avengers Endgame spoilers—nothing that you probably would not have guessed on your own. But, we would rather not be responsible for ruining a...more
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
IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more
The Congressional Research Service (CRS) has issued a report analyzing the economic effects of bonus depreciation. CRS has very little to say that is positive about bonus depreciation. CRS views it as neither an effective...more