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Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions in Final Legislation Impacting Domestic and Multinational Businesses

On July 4, 2025, President Trump signed H.R. 1, commonly known as the “One Big Beautiful Bill Act” (OBBB), into law. OBBB was initially approved by the House of Representatives on May 22, 2025 (the House Bill), followed by...more

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

Snell & Wilmer

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

Foodman CPAs & Advisors

Shareholders of S Corps can defer payment of Transition Tax

The Tax Cuts and Jobs Act (TCJA) includes a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”...more

Foodman CPAs & Advisors

Accionistas Estadounidenses que poseen el 10% o más tienen un mandatorio nuevo “impuesto de transición”

La "Ley de reducción de impuestos y empleos" (la "Ley") tiene una provisión que requiere que los Contribuyentes Estadounidenses que poseen el 10% o más de una Corporación Controlada Extranjera (Controlled Foreign...more

Foodman CPAs & Advisors

U.S. 10% Shareholder Taxpayers have a new Mandatory “Transition Tax”

The “Tax Cuts and Jobs Act” (the “Act") has a provision requiring U.S. Shareholder Taxpayers that own 10% or more of a Controlled Foreign Corporation (CFC) and other “Specified Foreign Corporations” to pay a “transition tax”....more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Orrick, Herrington & Sutcliffe LLP

Impacts on Foreign Operations That Affects Wholly-Owned and Majority Subsidiaries, And Potentially Minority Owned Stakes As Well

Summary: - On December 15, Congress released its final version of Tax Reform – the Conference Report Bill (the Bill). The Bill was signed into law by President Trump on December 22. ...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

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