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Venable LLP

SALT Alert: Senate Unveils Updated OBBBA SALT Cap Proposal

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On June 28, 2025, Senate Republicans released their updated version of the One Big Beautiful Bill Act (OBBBA), moving closer to finalizing their sweeping tax reform package ahead of a self-imposed July 4 deadline. A key...more

Cooley LLP

Treasury Department Asks Congress to Drop Proposed Legislation to Increase Tax Rates on Non-US Investors From Certain Countries

Cooley LLP on

On May 22, the US House of Representatives passed the “One Big Beautiful Bill Act” (OBBBA). Among other things, the House bill proposed to add Section 899 to the Internal Revenue Code, which would have increased US tax rates...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Pending Budget Bill reduces individual income tax rates, eliminates sales tax exemptions, and extends business tax credits;...

The Ohio Budget Bill for FY 2026-27 (H.B. 96) was agreed to by the Ohio House and Senate in Conference Committee and now awaits Governor DeWine’s signature. Consistent with the direction commenced a few years ago, the Budget...more

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

Whiteford on

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

Kelley Drye & Warren LLP

Proposed Section 899 - The Retaliatory Tax Regime

The One Big Beautiful Bill Act (the ​“Bill”), which was passed by the House of Representatives on May 22, 2025, contains a provision that, if enacted in its current form, would have a dramatic impact on the U.S. tax treatment...more

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

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

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On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more

K&L Gates LLP

Proposed Retaliatory US Taxes Would Impact Cross-Border Transactions

K&L Gates LLP on

Executive Summary - Retaliatory tax provisions contained in H.R. 1, the “One Big Beautiful Bill Act” that recently passed the US House of Representatives, if enacted, would drastically impact common cross-border transactions,...more

Sheppard Mullin Richter & Hampton LLP

U.S. Budget Bill Targets Foreign Companies with New Tax Hikes: What French Businesses Need to Know

The One Big Beautiful Bill Act (OBBBA) was passed by the U.S. House of Representatives on May 22, 2025 by a narrow vote of 215-214. OBBBA includes a new U.S. tax provision that could significantly increase taxes on foreign...more

Proskauer - Tax Talks

One Big Beautiful Bill Passed by the House

Proskauer - Tax Talks on

On Thursday May 22, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Bill”). The Bill will now be considered by the U.S. Senate....more

McDermott Will & Schulte

IRS Roundup May 2 – May 13, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 2, 2025 – May 13, 2025. IRS GUIDANCE - May 2, 2025: The IRS issued Revenue Procedure 2025-20, providing...more

Hogan Lovells

New Section 899 – Enforcement of remedies against unfair taxes

Hogan Lovells on

On May 12, 2025, the House Ways & Means Committee released legislative text for a new code section 899 designed to impose retaliatory tax measures against unfair foreign taxes, including digital services taxes and the...more

Brownstein Hyatt Farber Schreck

2025 Tax Bill – Summary and Analysis

On Monday, May 12, House Ways and Means Committee (“Committee”) Chairman Jason Smith (R-MO) released text of the Committee’s tax title for the FY 2025 budget reconciliation bill—the amendment in the nature of a substitute...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

Morrison & Foerster LLP

Koalitionsvertrag 2025 aus steuerrechtlicher Sicht

Die Koalitionsgespräche sind abgeschlossen. Wir geben einen ersten Überblick über die gemeinsamen steuerrechtlichen Ziele, die sich CDU/CSU und SPD als Koalitionspartner gesetzt haben. Die Koalitionspartner planen Änderungen...more

Goodwin

New Tax Measures Designed to Reinforce Luxembourg’s Attractiveness

Goodwin on

On 17 July 2024, the Luxembourg government introduced, under new Bill n° 8414, a comprehensive legislative package meant to modernise and enhance Luxembourg’s tax system. ...more

Stoel Rives - Mineral Law

Tax Actions by the Alaska Legislature in 2022

In my most recent column for State Tax Notes, I look at several bills that did and didn’t pass in the latest session of the Alaska State Legislature, which adjourned in May, and at what may be on the horizon....more

McDermott Will & Schulte

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Proskauer - Tax Talks

The Biden Administration Re-Proposes to Tax Carried Interests as Ordinary Income

Proskauer - Tax Talks on

On March 28, 2022, the Biden Administration proposed to tax “profits” or “carried” interests as ordinary income and impose self-employment tax on income and gains from these interests for certain partners in investment...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the U.S. International Tax Rules

Proskauer - Tax Talks on

Introduction and Summary - On March 28, 2022, the Biden Administration proposed changes to the U.S. international tax rules. In short, the Biden Administration proposed to: Enact a 15% minimum “undertaxed profits...more

Brownstein Hyatt Farber Schreck

Tax & Financial Services Week Ahead - April 4, 2022

The House and Senate will meet Monday at 2 p.m. and 3 p.m., respectively....more

Brownstein Hyatt Farber Schreck

Taxation & Representation, December 14, 2021

Senate Finance Committee Democrats Update Build Back Better. On Saturday afternoon, Senate Finance Committee Chair Ron Wyden (D-OR) released legislative text for the committee’s portion of the Build Back Better Act. The text...more

Proskauer - Tax Talks

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

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Yesterday, on December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage.  While there are no immediate prospects for the Build Back Better Act to...more

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